PERSONAL DATA PROTECTION POLICY OF WAON POINT PROGRAM

ARTICLE 1. GENERAL PRINCIPLES

This Personal Data Protection Policy described how Personal Data of Members participating in WAON POINT Program is collected and used within the scope of this Program in order to respect the privacy and security of the Members’ Personal Data. Unless otherwise defined herein, the capitalized terms shall have the meaning given to it in the Policy, Terms and Conditions of the WAON POINT program.
“We, Us, Our, Ours” collectively refer to ACSTV and the Participating Partners.
“ACSTV” is ACS Trading Vietnam Co., Ltd
“AEON Vietnam” (also referred to as "AEON VN", or "AVN", or "AEON Vietnam Co., Ltd.") is one of the WAON POINT Program’s Participating Partners.
The roles and identities of parties involved in processing Members’ Personal Data within the scope of the WAON POINT Program:

Each Participating Partner acts as a Data Controller in relation to the Member’s Personal Data collected by that Participating Partner via its Mobile Application and/or other methods described in Article 2 of this Personal Data Protection Policy. Specifically, a Participating Partner will determine the purposes and methods of processing the Member’s Personal Data collected by itself in order to serve the implementation of WAON POINT Program jointly held by all Participating Partners.
The list and details of Participating Partners are here and the Participating Partners will be announced time by time in accordance with current regulations.
ACSTV acts as a Data Controller and Data Processor. Specifically, ACSTV, on behalf of Participating Partners, will process Members’ Personal Data in order to implement and operate WAON POINT Program in accordance with the signed Agreements between ACSTV and the Participating Partners.
The details of ACSTV are specified in Article 10 of this Privacy Policy.

This Personal Data Protection Policy describes the following:

What kind of Personal Data We collect and how We collect such information;
Storage of Personal Data;
The purposes for which We collect and use Personal Data;
The parties to whom We disclose Personal Data;
The choices that We offer, including how to access and update the Personal Data;
Members’ rights and obligations regarding their Personal Data.

Before participating in the WAON POINT Program, Members must acknowledge thorough reading and agreement to the content of this Personal Data Protection Policy. By signing up for an account to participate in the WAON POINT Program on the Mobile Application, the Members confirm that they have been clearly and fully informed of and agree with all terms and conditions of this Personal Data Protection Policy of WAON POINT Program.
Members who connect with Us by the Mobile Applications on smartphone, will be required to give Personal Data. In addition, Members may also provide their Personal Data to Us via the methods described in Article 2 of this Personal Data Protection Policy.
We will verify the age of Members before collecting their Personal Data. Members agree to be responsible for the accuracy and truthfulness of the age information they provide. If you are a Child, you are requested to obtain consent from your parents or legal guardians before signing up for an account to participate in the WAON POINT Program on the Mobile Applications and submit any Personal Data to Us. If the parents and legal guardians become aware that their Child has provided his/her Personal Data to Us without their prior valid consent, they may contact Us to cease processing and/or irretrievably delete or destroy the provided Personal Data.
Members guarantee that all Personal Data submitted to Us is up-to-date, complete and accurate. Failure on your part to do so may result in our inability to provide Members with the products and/or services.
If Members believe that any of your Personal Data We are holding is out of date, incorrect or incompleted, please notify Us at the contact details specified in Article 10 hereunder.
Members are responsible for promptly notifying Us of any third party’s unauthorized usage, abuse, and security violations of Personal Data in order to respond appropriately.
This Personal Data Protection Policy is governed by and construed in accordance with the laws of the Socialist Republic of Vietnam. In case of raising any problem related to this Personal Data Protection Policy requires legal intervention, We will rely on this Personal Data Protection Policy to protect Our and/or the Members’ benefits.
This Personal Data Protection Policy is available in both English and Vietnamese. However, if there is any discrepancy between the English and Vietnamese versions, the Vietnamese version shall prevail.

ARTICLE 2. SCOPE OF INFORMATION COLLECTION

The Personal Data that We collect about Members includes but is not limited to:

Basic Personal Data: Members’ name, date of birth, gender, nationality, legal identification information (such as personal identification/ identity card/ citizen card/ passport number), address, phone number, details of account(s) registered on the Mobile Application, type of goods and/or services that the Members are interested in and such other necessary information in connection with the Members and Members’ transaction(s) with the Participating Partners and/or ACSTV that does not fall under the statutory categories of Sensitive Personal Data.
Sensitive Personal Data: means any information associated with an individual’s privacy and, if compromised, will directly affect such individual’s legitimate rights and interests, including information about Members’ location that has been obtained through location services upon Members’ access to and use of the Mobile Application: DO NOT COLLECT
Transaction Information: is information arising from or related to the process of shopping, using Member’s Accounts, performing transactions on the application and other channels of the Program.

We may obtain Personal Data of the Members from themselves through a variety of sources including but not limited to:

Information provided in application forms when the Members use Our goods or services, when the Members take part in Our customer surveys and other promotional programs;
Through the Members’ communications with Us in verbal, written forms or via e-mail;
From an analysis of the Members’ habits of using and managing the Members’ account(s) with Us, from the transactions, payments of the Members with Us;
From other sources that the Members agreed on the disclosure of their Personal Data for Us.

ARTICLE 3. STORAGE OF MEMBERS’ PERSONAL DATA

Storing and updating correct Personal Data is very important to Us. We retain the Members’ Personal Data during the implementation and after the expiration of the WAON POINT Program, for such a period as we deem appropriate, by maintaining physical, and digital protection methods in compliance with this Personal Data Protection Policy and/or the provisions of laws.

ARTICLE 4. PURPOSE OF COLLECTING AND USING MEMBERS’ PERSONAL DATA

This Personal Data that the Members provide is used to support Us in communication and contacting with the Members in order to provide goods/services and privilege to the Members within the framework of the WAON POINT Program.
In particular, We collect, store, use and/or process Members’ Personal Data for the following purposes:

To provide goods/deliver services to the Members;
To send notifications and conduct other information exchange activities between Us and the Members;
To notify the Members about important changes/developments to Our product/service features;
To organize, coordinate, and manage the WAON POINT Program; establish, develop, manage, and process a database of information on the Members, WAON Points, and other information related to the WAON POINT Program;
To communicate with the Members including responding to the Members’ enquiries and/or complaints and resolving disputes;
For the activities of strategic alliances, purchase, marketing, promotions and providing services by Our other units/departments/entities within the WAON POINT Program for the purpose of developing Our business activities and for the Members’ benefits;
To improve and develop Our services and assure the Members’ benefits;
To research and develop new goods and/or services;
To manage goods and services provided to Members and implement Our rights and obligations;
To comply with regulatory requirements and provide assistance to enforceable organizations;
To prevent, detect or denounce cases of fraud/crime in compliance with legal and regulatory regulations;
To process related agreements;
To comply with the legal obligations that We must follow;
To perform responsibilities for the common benefits of the parties involved in the WAON POINT Program;
For other legal purposes to the extent permissible by the Members and the applicable laws.
Identify, authenticate and verify Member’s information.
Store, manage, and reserve for disaster recovery or other similar purposes;
Use cookies or similar technologies to collect information such as: access history, Member's choices when accessing and using the features of the AEON VietNam Application... to enhance the experience and help AEON VN understands the needs and preferences of Member Customers to be able to provide better services.
For purposes of using Member’s information not mentioned above, the Company will notify Members before use, except in cases permitted by law.

We apply several measures to protect Members’ data and information as follows:

The database with its own access password is placed on DB server and is applied with measures such as FireWall, IP WhiteList and other methods guaranteed by DB server.
Assign specific departments and individuals to be in charge at connection points to access Member Information.
For internal actors: Develop a strict internal management policy on protecting Member Information, periodically check access permissions and extracted data.
Member Information on the AEON Vietnam Mobile Application is committed to be kept confidential by AEON VN in accordance with AEON VN's Privacy Policy. The collection and use of Member Information is only carried out with the consent of that Member, except for the cases specified of this Policy or other cases prescribed by law.
In the event that the AEON VN information storage server is hacked, resulting in the loss of Member Information data, AEON VN will be responsible for notifying the authorities to promptly investigate and handle the incident and notify the member.
Secure all online transaction information of Members, including accounting invoice information and digital documents in the AEON VN's level 1 secure central data area.
All Member Information, as well as information exchanged between Members and AEON VN, are stored and secured by AEON VN's system.
AEON VN has appropriate technical and security measures to prevent unauthorized access and use of Member Information. AEON VN also regularly coordinates with security experts to update the latest information on network security to ensure the safety of Member Information when Members access, register to open an account and/or use the features of the AEON VietNam Mobile Application. When collecting data, AEON VN stores and secures Member Information on the server system and this Member Information is secured by firewall systems, access control measures, and data encryption.
AEON VN does not allow third parties to monitor or collect Member Information on the AEON VietNam Mobile Application as well as on AEON VN websites, unless with the consent of the Member.
AEON VN commits to not force Members to use attached services by default when installing and using its application.

ARTICLE 5. SHARING THE MEMBERS’ PERSONAL DATA

By participating in the Program, the Members acknowledge and agree that:

Each Participating Partner may provide and share the Members’ Personal Data they collected under this Personal Data Protection Policy with other Participating Partners and ACSTV for the receiving parties to process for the purposes specified in Article 4.
We may provide or share the Members’ Personal Data with Our group companies, business partners, and other service providers within the framework of the WAON POINT Program on a need-to-know basis so that the receiving parties can process it for the purposes set out in Article 4. In case that any third parties are granted access to the database of the Members’ Personal Data, they will have to strictly comply with the rules described in this Personal Data Protection Policy, the regulations concerning the Personal Data and privacy protection.
For the purposes specified in Article 4, We may transfer Personal Data to third-party server providers who are based and/or locate their server systems outside the territory of Vietnam in order to centralize the Personal Data for universal, secure, and effective data management. With online access to the server system, We shall continue to be the party that directly processes Members’ Personal Data for the purposes specified in Article 4.
When transferring Personal Data outside of Vietnam (including but not limited to via cyberspace, electronic devices, electronic means, or other modes of transfer), we will request that the receiving third party ensure the safety and security of the transferred Personal Data.
We are responsible for cooperating with competent authorities to provide the Members’ Personal Data as legally required to do so.
We shall provide and share the Members’ Personal Data in such cases as regulated by laws to protect Our legitimate rights and interests.

ARTICLE 6. MEANS AND TOOLS FOR MEMBERS TO ACCESS AND EDIT THEIR PERSONAL DATA

Members have the rights to view, update and erase some certain Personal Data from the Mobile Application and/or to request Us to update the Personal Data from the PMS.
We may update and change data as requested and/or shall request the Members to provide supporting documents for verification.

ARTICLE 7. MEMBERS’ RIGHTS TO THEIR PERSONAL DATA

Members shall have the following rights in relation to their Personal Data as prescribed by the laws of Vietnam:

The right to be informed: In order to ensure the transparency of Member’s Personal Data collection according to Article 3 of this Personal Data Protection Policy, the collected information and the purposes of information collection will be published on the Mobile Applications or disclosed through supporting channels of the WAON POINT Program.
The right of access: Members have the right to ask Us to provide the Members’ Personal Data by sending the request to Our supporting departments.
The right to rectification: Members have the right to ask Us to update Members’ Personal Data or request Us to edit Personal Data that We collect incorrectly.
The right to erasure: Members have the right to ask Us to delete all Members’ Personal Data that We are storing.
The right to using restriction: In case some of Members’ Personal Data cannot be deleted, including for the purposes of doing the legal requirements, Members have the right to request Us to restrict using of this information.
The right to data portability: Members have the right to transfer Members’ Personal Data from one service to another with Us within the framework of the Program.
The right to objection: If We collect and use the Personal Data not for the purposes specified in this Personal Data Protection Policy without Members’ agreement, Members have the right to ask Us to stop using Members’ Personal Data until We have justified reasons for doing so, except at the request of the competent authority.
The rights in relation to automated decision making and profiling: Members may object or ask to explain Our automated decisions that affect Members or Members’ Personal Data.
The right to stop receiving newsletters from the Program: Members can choose to stop receiving marketing emails from the Program by unchecking "I would like to receive news" on Mobile Application.
The right to stop receiving notifications on the Mobile Applications from the setting on mobile device: Members can choose to stop receiving notifications on the Mobile Applications by customizing the permissions in the mobile device according to the rules of the platform such as iOS or Android.
Other rights of personal data subjects under the laws.

ARTICLE 8. OUR COMMITMENT AND MEMBERS’ OBLIGATION TO INFORMATION SECURITY AND PROTECTION OF PERSONAL DATA

Members’ Personal Data in the Program is ensured secure in accordance with this Personal Data Protection Policy. We only collect and use Members’ Personal Data whenever having Members’ agreement unless otherwise specified by laws. We implement technical, physical and organizational measures to prevent unauthorized access to Personal Data and loss, destruction, falsification, divulgence, and the like of Personal Data and endeavors to protect Members’ Personal Data through the establishment of a safety management system.
Potential unintended consequences and damage: Processing the Personal Data always carries the risk of data breaches or inappropriate data processing. We recognize the importance and responsibility of protecting Personal Data, making maximum efforts to prevent risks and limit any unintended consequences and damage to protect the Members’ and Our legitimate rights and interests. In case Mobile Applications and/or the PMS is hacked by hackers, resulting in the loss of Personal Data, We have the responsibility for investigation and giving prompt notice to the Members of process of resolving the incident.
Members are responsible for (a) ensuring that Personal Data that Members provide to Us is accurate, complete, not misleading and frequently updated; (b) do not provide any information related to account, password to the third party; (c) promptly notifying Us if Members discover or suspect that their Personal Data has been exposed, leading to risks in the use of Our services or any violations of Personal Data protection according to this Personal Data Protection Policy that Members can identify; (d) regularly checking Participating Partners’ Mobile Applications for updates and compliance with any changes (if any) related to this Personal Data Protection Policy; and (e) Other obligations as stipulated in current laws and regulations.
We are not responsible for as well as will not settle all complaints relating to Members’ benefits in case the Personal Data provided by the Members is incorrect of incomplete or in case the incident occurred due to Members’ fault.

ARTICLE 9. REVISIONS TO PERSONAL DATA PROTECTION POLICY

We reserve the right to revise this Personal Data Protection Policy to ensure the appropriateness with the Program and compliance with the applicable laws; however, We will not reduce Members’ rights under this Personal Data Protection Policy without their explicit consent. Every updated version of this Personal Data Protection Policy is available on Participating Partners’ Mobile Application with notifications displayed to Members. We will collect Members’ consent for the updated version. During the period before We obtain Members’ consent for the updated versions, Members’ Personal Data already collected by Us will continue to be processed in accordance with the Personal Data Protection Policy in effect at the time Members provided their prior consent.

ARTICLE 10. INFORMATION OF THE PERSONAL DATA COLLECTION AND MANAGEMENT UNIT

Should you wish to request for access to your Personal Data, request for amendment/correction of such Personal Data, request for exercise of any rights to your Personal Data, or provide any feedback to Us on this Personal Data Protection Policy, you may contact Us at the following address, phone number and/or e-mail:

ACS Trading Vietnam Company LTD.

Address: 246 Cong Quynh Street, Pham Ngu Lao Ward, District 1, Ho Chi Minh City
Hotline: 1900 5150 (ext: 2)
Email: waonpoint.support@acsvietnam.com.vn; or acs.support@acsvietnam.com.vn

ARTICLE 11. OTHER PROVISIONS

We reserve the right, at any time, to modify the content of this Policy at any time and such modifications shall be effective immediately upon posting and shall be recorded and reflected in the content of the policy on the Website or other official contact/information channels of the WAON Membership Points Program.

If any change, modification, addition or deletion of any part of this Policy adversely affects the rights and obligations of the Member, the Member has the right to request the cancellation of the Membership account, withdraw from the Program and/or delete previously provided information, except in cases where We must store it to perform obligations as prescribed by law.

The above is the Personal Data Protection Policy of the WAON Membership Points Program of ACSTV issued and updated by ACS Vietnam Trading Company Limited.

This policy is effective from October 7, 2024

Personal data protection policy of WAON Point program