DATA PROTECTION AND PROCESSING POLICY

I. General Principles:

1. This personal data protection and processing policy (“Data Policy”) describes how Netstars Vietnam Limited Liability Company (individually referred to as “Netstars Vietnam”; collectively as “Company” or “we”) processes User Information in compliance with the applicable laws (“Processing”) and ensures the security of information for organizations and individuals (“Users”) in compliance with the applicable laws on information/data security. This privacy policy (“Policy”) is established to govern how we collect, use, disclose, store, and/or process data when users access the teteshop.net website, and our official TeteShop application on the Android or iOS platforms, as well as all related webpages (collectively referred to as the “Platform”).

By using our Services, registering an Account with us, or accessing our Platform, you confirm and consent to allow us to collect, use, disclose, and/or process your personal data as stipulated in this Policy.

2. Data Processing Subject and Securing User Information and Relationships:

• • The Account Service is one of our Services, including but not limited to the feature of creating an account within the Netstars Vietnam ecosystem that we provide, enabling customers to log in and use utilities and features on the platform.
  • Any User Information arising from or related to the Service will be processed and secured by us as stipulated in this Data Policy. In the case that the Company terminates the cooperative relationship to provide the Service, the consent of the User, collected by the parties under this Data Policy, for User Information collected before the termination, shall remain in effect independently for each party.
  • Please carefully read this Data Policy, the corresponding terms and conditions, and other regulations (if any).

3. This Data Policy does not apply to any products, services, websites, or content provided by third parties or those that use their own Data Policy.

4. “User Information” refers to various types of personal data, including basic and sensitive personal information, as stipulated by the current laws. This encompasses information related to Users or data that can be used to identify and recognize Users. For example, this information may include names, nationality, telephone numbers, details of payment cards and banks, personal preferences, email addresses, locations, images, business registration information, ID cards/citizenship cards, date of birth, marital status, insurance information, transaction history, browsing history, customer journey, addresses, geolocation, store images, and Users’ business location information. Additionally, in some cases, sensitive information such as race, health, religious beliefs, political opinions, and biometric data may be collected when necessary.

5. Users have read, understood, and agreed to the entire content of this Data Policy. The Company has the right to amend, supplement, or update this Policy at any time. Please regularly check this privacy policy to keep up with any changes or adjustments. User’s continued use, access to the Interaction Channel, or the provision/use of the Services shall be understood as the User’s consent to the amended, supplemented, and/or updated contents of this Data Policy.

6. Users have the right to refuse to use the services or access/use our Platform if they do not agree to allow us to process their data as stipulated in this policy.

7. The terms in this Data Policy apply equally to both singular and plural forms of the defined terms. The term “including” shall be deemed to accompany the phrase “without limitation.”

8. Users understand that, as stipulated by the current laws, we have the responsibility to collect, use, or store User Information in certain specific situations, including but not limited to when required, consulted, proposed, or requested by legal advisors or compliance with legal regulations, documents under the law, or requests from the government or competent authorities in Vietnam or other countries. These tasks include, but are not limited to, disclosing information, reporting as required by the legal regulations on promotion, record-keeping, auditing, investigation and settlement of complaints or disputes, complying with court orders or legal requirements, and protecting our rights and property in the event of complaints or disputes.

II. User Information Collected

We collect necessary User Information during the provision and use of our Services for/from the users.

The types of information we collect and how we collect it are as follows:

1. User-provided information: We collect any information that users provide related to the Services.

• In various cases, including: (i) registering for an account, logging in, interacting with features, registering/using Services on the Platform, or from third-party partners through our Platform; (ii) using any available features on the Platform; (iii) using biometric features for user identification, transaction verification; (iv) sharing location information, uploading images, videos, sharing location-tagged photos; (v) through customer care calls, introductions, promotions, feedback, complaints, and/or (vi) conducting surveys, investigations; (vii) when providing personal information for any reason.
• Types of information collected (including but not limited to): (i) account information such as name, address, gender, date of birth, profile picture, mobile phone number, phone book; (ii) data when accessing and/or using the Platform, such as IP address, browser information, visited addresses on the Platform, user activity time on our Platform; (iii) device information used on the Platform, such as device type, operating system, operating system version; (iv) location data, such as user device location and/or any location information uploaded as images or videos on the Platform; (v) any other data or information disclosed by users when they log in, use our Services, and our Platform; (vi) other aggregated data about the content users use; (vii) information shared from third-party partners when users accept to use the services provided by these partners through our Platform; (viii) data about the third parties providing, using, selling services or goods for users, transaction information that users and users’ customers conduct on the Platform and at users’ business locations (such as categories, specifications, codes, images, prices, quantity of goods and services traded, location, transaction time, policies and applicable promotions for such goods and services), user payment methods and users’ customers.
• Users hereby understand and agree that calls, messages, and/or other forms of contact to and/or from us will be stored in the form of recording, video recording, automatic or manual methods, for the purpose of supporting requests, updating information systems, improving service quality, and other legitimate purposes.
• Users are responsible for ensuring that the information they provide is complete, accurate, not misleading, and continuously updated to ensure the users’ rights in accordance with the provision and use of the corresponding Services. The Company is not responsible in cases where users provide inaccurate or incomplete information in accordance with the Services’ requirements.
• For users under the age of 16, we ensure that they have informed their parents or legal guardians about the terms of this Data Policy in detail and have full consent and full commitment from their parents or legal guardians to provide User Information to the Company. And at the same time, parents or legal guardians must agree and commit to comply with the terms of this Data Policy, as well as be responsible for the actions of users under the age of 16 that they are guardians of. The Company is authorized to deny access to the Platform or provide/use related Services if there is a basis to believe that the user is under 16 years old and does not have consent and approval as mentioned from their parents or legal guardians.
• In cases where users provide third-party information, users guarantee and ensure that they have clearly informed the third party of the contents in this Data Policy and have obtained full consent and approval from that third party for providing information to the Company and for the Company to use that information in accordance with the provisions of this Data Policy.
• Users ensure and commit that the information provided to the Company does not belong to any of the following categories: (i) state secrets, (ii) business secrets; and (iii) any other information that users are not allowed to provide by law or confidentiality agreement.
• Providing User Information to us is not a legal requirement, a contractual requirement, or a condition for signing a contract. Users are not obliged to provide the User Information we have requested. However, in many cases, we may not be able to provide or use our Services for users or meet the users’ requests if users choose not to do so.

2. Automatic Information Collection: We automatically collect certain types of information when users interact with the Services.

3. Collection and Use of Cookies: We may use automated methods, such as cookies, tags, ad identifiers, or other automated methods (collectively referred to as “Cookies”) related to the use of the Platform to enhance the User Experience during the use of Services, through the following specific features:

• • Identify users when they log in to use/provide Services. This allows us to provide users with personalized suggestions, display personalized content, and provide other custom features.
  • Save the permissions that users have accepted. This allows us to respect the preferences of users, such as language options and user configurations.
  • Conduct research and analysis to improve our services.
  • Prevent fraudulent behavior.
  • Improve security.
  • Provide content, including advertising, related to user preferences on our and third-party websites.
  • Measure and analyze the quality of our Services.

• Cookies enable users to take advantage of some essential features. For example, if users block or refuse our cookies, users may not be able to use certain products, certain services that require users to log in, or users may need to manually adjust some options or language settings each time they access the Platform.
• Approved third parties may also set cookies to collect User Information when users interact with Services. These third parties typically include search engines, measurement and analysis service providers, social networks, and advertising companies. Third parties may link the User Information they collect with other User Information they have from other sources. We do not necessarily have the right to access or control their use of cookies.
• Users can manage and delete cookies through browser settings or device settings. However, please note that if users do this, they may not be able to use all the features of the Platform or our Services.

4. Physical Location Information Collection: We may, on our own or through partners, contractors, service providers, collect information, images about users’ business locations and business activities, including but not limited to location positioning, traffic characteristics, layout around business locations, signs, designs, decoration and presentation methods of business locations, customer density, types of goods and services provided, and other information, images related to the location of the users.

5. Information from Other Sources: We may collect User Information from other sources, including service providers, partners, referral programs, when users add third-party information in surveys, investigations, promotional programs, or similar forms and publicly available sources. When we collect User Information from other sources, we ensure that the data is transferred to us in accordance with applicable law.

III. How We Store and Protect User Information

At the Company, security is our top priority. All User Information is stored and secured by the Company’s system or service providers according to the provisions of the law and this Data Policy.

IV. How We Use User Information

1. Users here agree that User Information collected under this Data Policy will be published and used with the user’s consent for the purposes outlined in Section 3 below.
2. We do not have a policy or practice of providing User Information to any other organizations or companies for their direct marketing purposes or any other purposes, except for the use of information as stipulated in this Data Policy.
3. We Process User Information to provide products, Services, and ensure the safe, continuous, and full-featured use of User Services (“Purposes”), including maintaining, enhancing products, Services, and protecting, enhancing the User experience, such as:
   • To verify user identity.
   • To contact for customer support purposes to provide our Services.
   • To provide official information to buyers contacting users when making a sale.
   • To check and evaluate data on our platform.
   • To identify users and manage account information.
   • To determine user access on the platform.
   • To detect and prevent fraudulent activities.
   • To conduct marketing research activities.
   • To research and analyze demographics.
   • To send notifications that we deem necessary or users would be interested in unless users opt out of receiving these notifications.
   • To analyze and evaluate to improve and enhance our Services.
   • Storing the history of conversations we have for a certain period of time in accordance with legal regulations at any given time to serve content management and enhance the user experience.
   • Any other purposes that we inform the user of and receive the user’s permission for at the time. For purposes of using User Information not mentioned above and/or requiring specific user consent, we will seek the user’s permission for a specific purpose when contacting the user.

V. How We Share User Information

1. User Information is an integral part of our operations, and we do not sell User Information to any third party. We only share User Information for the Purposes outlined in this Data Policy. Parties receiving shared access to User Information must strictly adhere to the legal provisions and regulations related to this Data Policy. Accordingly, User Information may be shared with the following parties and under the circumstances:
   • Complying with the requests of competent state authorities or legal provisions.
   • Sharing User Information with other Users when Users use interactive tools on the Platform.
   • Providing, sharing User Information with partners at the request or confirmation of Users, through various electronic means on the Platform or other forms.
2. We may provide User Information to service providers, consultants, marketing partners, research companies, and other business partners. This includes but is not limited to payment processing departments and support departments, anti-money laundering services, cloud storage service providers, data analytics providers, research partners, insurance, finance, and banking partners, manufacturers, suppliers, and distributors of services, goods, products provided to Users under the scope of Services.
3. Transferring, providing, and sharing User Information with consultants, experts, service providers, Company’s subcontractors: The Company may transfer User Information to consultants, experts, and subcontractors to perform jobs and provide services that are in line with the intended use.
4. Providing, sharing, displaying some User Information (including but not limited to location information, contact information, and images of stores, goods, and User services) to customers, Company partners, and companies on the TeteShop Application and other Company websites and platforms for promotional, cooperation, display, communication, introduction, and provision of Users’ products/services, Company products/services, and other promotional programs to promote and advertise the Company’s business activities and Users.
5. Business Transfer: In the process of business development, we may buy or sell other businesses or services. In such transactions, User Information, in general, is one of the transferred business assets but still has to comply with the provisions of this Data Policy (or when the customer agrees). Furthermore, in cases where the Company or the majority of the Company’s assets are purchased by another company, User Information will naturally become one of the transferred assets.
6. Disclosure of accounts and User Information when we believe it is appropriate to comply with the law, to enforce or apply other terms and agreements, or to protect our rights, property, or security, Users, or any other individuals. The above-mentioned activities may include exchanging information with other companies and organizations to prevent and detect fraud and reduce risks.
7. In other cases, users will be notified when User Information may be shared with third parties, and users have the right to withhold consent for sharing information.

VI. User Rights and How to Invocate these rights

1. Users may view, update, and delete certain account and user interaction information. If users cannot access or update their information themselves, they can always contact us for assistance. Moreover, users can request that we exercise their other rights according to legal regulations by contacting us through the support channels below.
2. Users have many choices regarding the collection and use of User Information. Many Services include features that allow users to choose how their information is used. Users may choose not to provide certain information, but doing so may limit their access to some Services. Please follow the Company’s instructions at any given time.
3. Account information: If users wish to supplement, update, or delete information related to their accounts, please follow the Company’s instructions at any given time.
4. Browsers and devices: Help features on most browsers and devices will inform users how to prevent their browsers or devices from accepting new Cookies, how to notify users when they receive new Cookies, or how to disable Cookies entirely.

VII. Contact Information, Notifications, and Modifications

1. Our business operations are constantly changing, and this Data Policy may also be amended. Users should access and check the Platform regularly to update the latest changes. The Company has the right to amend, update, or adjust the terms of this Data Policy at any time by posting updated Data Policy on the related Platform. By continuing to use the Service after any modifications, updates, or adjustments to this Data Policy, Users express acceptance of those modifications, updates, or adjustments.
2. If users have any questions about information security at the Company or want to contact our data controller, please contact us, and we will try to answer users’ questions. Users can also contact us by calling the hotline: 098690870 or emailing to info@netstars.vn.