Privacy Policy of Viet Depot Equiment Joint Stock Company
Effective Date: August 12, 2024
Viet Depot Equiment Joint Stock Company and subsidiaries (“we”, “us”,“our”, “Viet Depot Equiment Joint Stock Company”) are committed toprotecting your privacy. This Privacy Policy (“Policy”) describes our practicesin connection with information privacy on Personal Data we process through yourindividual use of the following services, products, and related mobile applications(collectively, the “Products”):
·VietSmart Mobile Application
Before you use our Products, please carefully readthrough this Policy and understand our purposes and practices of collection,processing of your Personal Data, including how we use, store, share andtransfer Personal Data. In the Policy you will also find ways to execute yourrights of access, update, delete or protect your Personal Data.
When you accept this Policy when you register withyour Personal Data, or if you start to use our Products and does not expresslyobject to the contents of this Policy, we will consider that you fullyunderstand and agree with this Policy. If you have any question r regardingthis Policy, please do not hesitate to contact us via:
Definition
In this Policy, Personal Data means informationgenerated, collected, recorded and/or stored, electronically or otherwise, thatcan be used to identify an individual or reflect the activity of an individual,either from that information alone, or from that information and otherinformation we have access to about that individual.
Personal Sensitive Data includes personal biometricinformation, communication records and contents, health information,transaction information, and precise location information. When we collectPersonal Sensitive Data from you, we will generate an explicit notification foryour consent before we collection personal sensitive data about you.
Smart Devices refers to those computing devicesproduced or manufactured by hardware manufacturers, with human-machineinterface and the ability to transmit data that connect wirelessly to anetwork, including: smart home appliances, smart wearable devices, smart aircleaning devices, etc.
Apps refers to those mobile applications developed by Viet Depot Equiment Joint Stock Company thatprovide end users remote control to Smart Devices and with the ability toconnect to the supplier IoT Platform.
What Personal Data do we collect
In order to provide our services to you, we will askyou to provide necessary Personal Data that is required to provide thoseservices. If you do not provide your Personal Data, we may not be able toprovide you with our products or services.
1.Information You Voluntarily Provide Us
· Registered Account Data: When youregister an account with us, we may collect your name and contact details, suchas your email address, phone number, user name, and login credentials. Duringyour interaction with our Products, we may further collect your nickname,profile picture, country code, language preference or time zone informationinto your account.
· Non-registered Account: If you donot want to provide your account data when you start to use any of theServices, you may use the App without logging in or creating an account, namelythe “Try Now” mode, and you may still use certain Services, such as searchingand browsing any features on the App by creating a guest ID. When you are usingthe "Try Now" mode, we will not collect Personal Data related to youraccount. Collection and use of the Personal Data collected here will be limitedto: the time of entering the App, operating system of your mobile phone, andthe purposes you have authorized in using the additional functions of the Appand/or the Smart Devices. For instance, if you enable the location setting inthe "Try Now" mode, the location data will be uploaded for supportingthe function. Once you exit from the "Try Now" mode, we will removeyour data instantly and permanently.
However,if the Services you request or purchase are based on your account, please go tothe registration/login page for guidance.
Information based on additional functions:
In order to offer you with more convenient andhigher-quality Services with optimized user experiences, we may collect and usecertain information if you consent to use additional functions in the App.Please note, if you do not provide such information, you may continue to usebasic Services of the App and connected Smart Devices, but certain featuresbased on these additional functions may not be available. These additionalfunctions may include:
1)Additionalfunctions based on location information:
When you enable the location-based functions throughpermission settings on your mobile device, we will collect and process yourlocation information to enable these functions, such as pairing with your SmartDevices. Also, we may collect information about your: a) real-time and preciselocation, for instance when you choose to use the automation scenarios forcontrolling your Smart Devices, or b) non-precise geo-location when you usecertain Smart Devices or the Services, such as robot cleaner and weather service.
Based on your consent, when you enable the geo-fencefeature, your location information will be generated and shared with GoogleMaps services. Please note that Google has corresponding data protectionmeasures, which you may refer to Google’s Data Processing and Security Termsfor more details.
You may disable the collection and use of yourlocation information by changing your mobile device settings ("My - Setting - Privacy Right Setting - Switchon/off Location Information"), upon which we will cease to collectand use your location information.
2)Additionalservices based on camera:
You may use the camera to scan the code by turning onthe camera permission to pair with a Smart Device, take video, etc. Please beaware that even if you have agreed to enable the camera permission, we willonly obtain information when you actively use the camera for scanning codes,video recording, etc.
You may opt-out the using of camera permission: "My - Setting - Privacy Right Setting - Switchon/off Camera".
3)Additionalservices for accessing and uploading pictures/videos based on photo albums(picture library/video library):
You can use this function to upload yourphotos/pictures/videos after turning on the photo album permission, so as torealize functions such as changing the avatar, reporting device usage problemsby providing photo proofs, etc.. When you use the photos and other functions,we will not recognize this information; but when you report a device usageproblem, we may use the photos/pictures you upload to locate your problem.
You may opt-out the using of photo album permission: "My - Setting - Privacy Right Setting - Switchon/off Photo Album".
4)Additionalservices related to microphone-based service:
You can use the microphone to send voice informationafter turning on the microphone permission, such as shooting videos, waking upthe voice assistant, etc. For these functions, we will collect your voiceinformation to recognize your command. Please be aware that even if you haveagreed to enable the microphone permission, we will only obtain voiceinformation through the microphone when you voluntarily activate the microphonein the App.
You may opt-out the using of microphone permission: "My - Setting - Privacy Right Setting - Switchon/off Microphone".
5)Additionalservices based on storage permission(Android):
The purpose is to ensure the stable operation of theApp by utilizing the storage permission. After you give or indicate thepermission to read/write your mobile device’s storage, we will access pictures,files, crash log information and other necessary information from your mobiledevice’s storage to provide you with functions, such as informationpublications, or record the crash log information locally.
You may opt-out the using of storage permission: "My - Setting - Privacy Right Setting - Switchon/off Storage".
6)Additionalservices based on Notification permission:
The reason why we ask you for the permission is tosend you notifications about using the Smart Devices or Services, especially ifyou have purchased security services and you require an alert or message sothat you can capture the real-time status.
You may opt-out the using of App notifications: "My - Message Center - Setting - Switch on/offNotifications".
7)Additional services based on Alert Window permission：
You may choose to bind a camera in the App andrequire the App to display the real-time image of the camera in a separatewindow.
You may opt-out the using of alert windowinformation: "My - Setting - PrivacyRight Setting - Switch on/off Alert Window".
8)Additional services based on Bluetooth permission:
You can enable Bluetooth functions after turning onthe permission, including controlling the Smart Devices, acquiring status of,discovering and configuring Smart Devices. In these functions, we willcommunicate with Smart Devices via Bluetooth. Please be aware that even if youhave agreed to enable the Bluetooth permission, we will only use Bluetooth forcommunication in these scenarios: display device status on the home page andSmart Device panel; perform device control on the home page and Smart Devicepanel; discovering Smart Devices on the home page and the add device page,Smart Device distribution network.
You may opt-out the using of Bluetooth via "My - Settings - Privacy Setting -Disable/Enable Bluetooth permission".
2.Information We Collect Automatically
· MobileDevice Information: When you interact with ourServices, in order to provide and maintain the normal operation of ourServices, to improve and optimize our Services, and to protect your accountsecurity as well, we automatically collect mobile device information, such as mobiledevice model number, IP address, wireless connection information, the type andversion of the operating system, application version number, pushnotification identifier, log files, and mobile network information. Meanwhile,we will collect your software version number. In order to ensure the securityof the operating environment or to provide services, we will collectinformation about the installed mobile applications and other software you use.
· UsageData: During your interaction with our websites andServices, we automatically collect usage data relating to visits, clicks,downloads, messages sent/received, and other usage of our websites andServices.
· LogInformation: When you use the App, in order to improve your userexperience, the system and exception log may be uploaded, including your IPaddress, language preference setting, operating system version, date or time ofaccess, so that we can facilitate and accurately identify problems and help yousolve them in timely manner.
Please note that we cannot identify aspecific individual by using device information or log information alone.However, if these types of non-personal information, combined with otherinformation, may be used to identify a specific individual, such informationwill be treated as Personal Data. Unless we have obtained your consent orunless otherwise provided by data protection laws and regulations, we willaggregate or desensitize such information..
3.Smart Devices Related Information:
· BasicInformation of Smart Devices: When you connect your SmartDevices with the Services, we may collect basic information about your SmartDevices such as device name, device ID, online status, activation time,firmware version, and upgrade information.
· Informationcollected during the process of connecting to a Smart Device:Based on the type of Smart Device you need to connect, the basic informationcollected includes: Wi-Fi information, device MAC address, etc.
· InformationReported by Smart Devices: Depending on the differentSmart Devices you elect to connect with our Products or Services, we maycollect different information reported by your Smart Devices. For example, Please enter information about the smartdevice report.
Purposes and legal basis for processing Personal Data
The purpose for which we may process informationabout you are as follows:
· ProvideYou with Our Services: We process your account data,mobile device information, usage data, location information, and Smart Devicerelated information to provide you with the Services that you have requested.The legal basis for this processing is to perform our contract with youaccording to user agreement.
· ImproveOur Services: We process your mobile device information, usagedata, location information and Smart Device related information to ensure thefunctions and safety of the Services, to develop and improve the Services, toanalyze the efficiency of our operations and to prevent and trace fraudulent orinappropriate usage. The legal basis for this processing is to perform ourcontract with you according to our useragreement.
· Non-marketingCommunication: We process your Personal Data to send you importantinformation regarding the Services, changes to our terms, conditions, andpolicies and/or other administrative information. At the same time, we willalso send you notifications related to the services you have purchased, such asalert services. You can check the “App Notification” in the App ("Me &rt; Message Center &rt; Setting &rt;Notification Setting”) to manage these communications. When you decidenot to enable the Notifications function, we will no longer process yourinformation for such purpose. The legal basis for this processing is to performour contract with you according to our useragreement.
· DataAnalysis: In order to analyze the usage of the products weprovide and improve your user experience, we will analyze the data you provideus, a) we need to check your problems when you encounter any malfunctionsduring the usage of the product, under such circumstance, you may not able toopt-out because it is highly relate to your functionalities and quality ofusing our product and service, and b) analyze data about how you interface withthe product or under particular scenarios so that you can better enjoy the conveniencebrought by our Services, under such circumstance, if you do not agree to dataanalysis of your data, you can enter the privacy settings of App (“My &rt; Settings &rt; Privacy Settings &rt; DataAnalysis”) to opt-out your selection. The legal basis for suchprocessing is based on your consent.
· MarketingCommunication and Personalization: We mayprocess your account data, usage data, device information to personalizeproduct design and to provide you with services tailored for you, such asrecommending and displaying information and advertisements regarding productssuited to you, and to invite you to participate in surveys relating to your useof the Services. If you do not allow us to process your Personal Data forpersonalization, you may opt out when you enter the App, or by changing yourpreferences in “Privacy Settings” (“Me&rt;Settings &rt; Privacy Settings &rt; Personalization”) in the App. Thelegal basis for this processing is your consent.
· LegalCompliance. We disclose information if we are legally requiredto do so, or if we have a good faith belief that such use is reasonablynecessary to:
· comply with a legal obligation,process or request;
· enforce our User Agreement andother agreements, policies, and standards, including investigation of anypotential violation thereof;
· protect the rights, property orsafety of us, our users, a third party or the public as required or permittedby law; or
· detect, prevent or otherwiseaddress security, fraud or technical issues.
If there is any change in the purposes for processingyour personal data, we will inform such change to you via email and/or aprominent notice on our website of such changes of purposes, and choices youmay have regarding your Personal Data.
Who do we Share Personal Data with?
At Viet Depot Equiment Joint Stock Company, weonly share Personal Data in ways that we tell you about. We may share yourPersonal Data with the following recipients:
· To our third-party serviceproviders who perform certain business-related functions for us, such aswebsite hosting, data analysis, payment and credit card processing,infrastructure provision, IT services, customer support service, e-maildelivery services, and other similar services to enable them to provideservices to us.
· To our customers and otherbusiness partners who provide you, directly or indirectly, with your SmartDevices, and/or networks and systems through which you access and use ourwebsites and Services.
· To subsidiaries or affiliateswithin our corporate family for purpose of regular business activities based onour instructions and in compliance with applicable law, this Policy and otherappropriate confidentiality and security measures.
· To an affiliate or other thirdparty in the event of any reorganization, merger, sale, joint venture,assignment, transfer or other disposition of all or any portion of ourbusiness, assets or stock (including without limitation in connection with anybankruptcy or similar proceedings). In such an event, you will be notified viaemail and/or a prominent notice on our website of any change in ownership, andchoices you may have regarding your Personal Data.
· As we believe in good faith thataccess to, or use, preservation, or disclosure of the information is reasonablynecessary or appropriate to:
(a)Complywith applicable law, regulation, legal process, or lawful governmental request;
(b)Enforceour User Agreement and other agreements, policies, and standards, includinginvestigation of any potential violation thereof;
(c)Protect our operation and business systems;
(d)Protectthe rights, property or safety of us, our users, a third party or the public asrequired or permitted by law; or
(e)Performrisk management, screening and checks for unlawful, fraudulent, deceptive ormalicious activities.
Except for the third parties mentioned above, we onlydisclose your Personal Data to other third parties with your consent.
International Transfer of Information Collected
Viet Depot Equiment Joint Stock Companywill comply with applicable data localization requirements incorresponding jurisdictions with respect to storage of data. To facilitate ouroperation, we may transfer, store and process your Personal Data injurisdictions other than where you live. Laws in these countries may differ fromthe laws applicable to your country of residence. When we do so, we will ensurethat an adequate level of protection is provided for the information by usingone or more of the following approaches:
· Agreement on the basis ofapproved EU standard contractual clauses per GDPR Art. 46. For moreinformation,see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
· Please add if there is anyinternational transfer mechanism you are relying on, for instance PrivacyShield.
If you would like further detail on the safeguards wehave in place, you can contact us directly as described in this Privacy Policy.
Your Rights Relating to Your Personal Data
We respect your rights and control over your PersonalData. You may exercise any of the following rights:
via the privacy office email address; Contact@vietdepot.vn or via the route ofFeedback imbedded in the App: Me -&rt; PersonalCenter -&rt; Accountand Security, etc.
You do not have to pay a fee and we will aim torespond you within 30 days. If you decide to email us, in your request, pleasemake clear what information you would like to have changed, whether you wouldlike to have your Personal Data deleted from our database or otherwise let usknow what limitations you would like to put on our use of your Personal Data.Please note that we may ask you to verify your identity before taking furtheraction on your request, for security purposes.
You may:
· Request access to the PersonalData that we process about you: "My-Setting-Privacy Settings-Personal DataExport";
· Request that we correctinaccurate or incomplete Personal Data about you: 1) Modify your account number(email address or phone number): "My-Setting-Accountand Security-Change your Account"; 2) Modify the nickname and/ortime zone: "My-Personal Information";
· Request deletion of Personal Dataabout you: "My-Setting-Account andSecurity-Delete Account", when you confirm the deletion of youraccount, your Personal Data will be deleted accordingly.
· Request restrictions, temporarilyor permanently, on our processing of some or all Personal Data about you:Please send over your request through "My-FAQ& Feedback", or send over the email request toContact@vietdepot.vn;
· Request transfer of Personal Datato you or a third party where we process the data based on your consent or acontract with you, and where our processing is automated: Please send over yourrequest through "My-FAQ &Feedback", or send over the email request to Contact@vietdepot.vn;
· Opt-out or object to our use ofPersonal Data about you where our use is based on your consent or ourlegitimate interests.
We will exercise your privacy right to withdrawconsent through the following approaches:
1)For privacy permissions acquired through devicesystem settings, your consent can be withdrawn by changing device permissions,including location, camera, photo album(picture library/video library), microphone, Bluetooth settings, notificationsettings and other related functions;
2)You may opt-out the non-marketing communicationthrough “Me &rt; Message Center &rt;Notification Settings” to manage your selection;
3)You may opt-out the data analysis features through “Me &rt; Settings &rt; Privacy Settings”;
4)You may opt-out the Personalization feature through“Me &rt; Settings &rt; Privacy Settings &rt;Personalization”;
5)Unbind the Smart Device through the App, and theinformation related to the Smart Device will not be collected;
6)By using product with the "TryNow" mode, and not enable certain location setting forparticular smart scene, we will not collect any Personal Data about you;
7)If you previously agreed to associate App accountwith a third-party service, such as a health platform, please unbind it on thethird-party platform.
When you withdraw your consent or authorization, wemay not be able to continue to provide you with certain products or servicescorrespondingly. However, your withdrawal of your consent or authorization willnot affect the processing of personal information based on your consent beforethe withdrawal.
About Deletionof the Account: You can find the Delete function through “Me &rt; Settings &rt; Account and Security &rt;Delete Account” (Deactivate Account）
Security Measures
We use commercially reasonable physical,administrative, and technical safeguards to preserve the integrity and securityof your Personal Data. Viet Depot Equiment Joint Stock Company providesvarious security strategies to effectively ensure data security of user anddevice. As for device access, Viet Depot Equiment Joint Stock Company proprietaryalgorithms are employed to ensure data isolation, access authentication,applying for authorization. As for data communication, communication usingsecurity algorithms and transmission encryption protocols and commerciallevel information encryption transmission based on dynamic keys aresupported. As for data processing, strict data filtering and validation andcomplete data audit are applied. As for data storage, all confidentialinformation of users will be safely encrypted for storage. If you have reasonto believe that your interaction with us is no longer secure (for example, ifyou feel that the security of any account you might have with us has beencompromised), you could immediately notify us of the problem by emailing Contact@vietdepot.vn.
Data Retention
We process your Personal Data for the minimum periodnecessary for the purposes set out in this Policy, unless there is a specificlegal requirement for us to keep the data for a longer retention period. Wedetermine the appropriate retention period based on the amount, nature, andsensitivity of your Personal Data, and after the retention period ends, we willdestruct your Personal Data.
· For as long as you require us tofulfill the products and services you request from us as defined in the user agreement;
· Personal Data will no longer beretained when you request to remove your Personal Data, we will accordinglycomplete the task.
When we are unable to do so for technical reasons, wewill ensure that appropriate measures are put in place to prevent any furthersuch use of your Personal Data.
Children’s Privacy
Protecting the privacy of young children isespecially important to us. The Services are not directed to individuals underthe age of thirteen (13) (or such other age provided by applicable law in yourcountry/region of residence), and we request that these individuals do notprovide any Personal Data to us. We do not knowingly collect Personal Data fromany child unless we first obtain permission from that child’s parent or legalguardian. If we become aware that we have collected Personal Data from any childwithout permission from that child’s parent or legal guardian, we will takesteps to remove that information..
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changesto our information practices. If we make any material changes we will notifyyou by email (send to the e-mail address specified in your account) or by meansof a notice in the mobile applications prior to the change becoming effective.We encourage you to periodically review this page for the latest information onour privacy practices.
Contact Us
If you have any questions about our practices or thisPrivacy Policy, please contact us as follows:
Email: Contact@vietdepot.vn