Personal Data

We, Vua Thợ TECHNOLOGY CO., LTD (hereinafter referred to as 'Vua Thợ' or 'we'), highly value privacy and the protection of users' personal data.

This Privacy Policy of Vua Thợ TECHNOLOGY CO., LTD ('Vua Thợ') will provide information on how Vua Thợ collects and processes, stores users' personal data for the purpose of providing Vua Thợ's products and/or services or conducting business transactions with users, and when users use Vua Thợ's online services. This policy explains why we collect users' personal information, how it is used, who it may be shared with, how users can access, view, and modify their personal information. Additionally, this policy outlines the expected standards and control procedures for protecting Personal Data in line with policy objectives. We will also inform users of their rights and how to contact us.

To avoid confusion, this data privacy policy applies only to individual users. Vua Thợ encourages users to carefully read this policy and regularly check our website for any updates that Vua Thợ may implement according to the policy's terms.

Definitions

For the purpose of this policy, please note the following definitions:

“Vua Thợ” means “Vua Thợ TECHNOLOGY CO., LTD”established as a limited liability company with a single member, effective from the date of issuance of the Certificate of Establishment and Operation, and operating in accordance with the laws of Vietnam.

“Data Processing”means collecting, recording, analyzing, verifying, storing, amending, publicizing, combining, accessing, retrieving, recovering, encoding, decoding, copying, sharing, transmitting, providing, transferring, deleting, or other actions related to personal data of Clients/Partners.

“Personal Data”refers to any information directly or indirectly related to Users, and/or Users' transactions with us. Personal data includes basic personal data or sensitive personal data.

“Users” are individuals who access, inquire, register, use, or are involved in the operation process, providing products or services of Vua Thợ.

“Third Party”refers to organizations, individuals other than Vua Thợ and Users as explained in this policy.

“Personal Data Protection” includes prevention, detection, prevention, handling of violations related to personal data as required by law.

“Applicable Law” means the legal regulations of the Socialist Republic of Vietnam issued, amended, supplemented from time to time to regulate personal data protection activities.

Please note that information that we cannot use to identify the data subject is not considered Personal Data. Providing personal data from users to Vua Thợ is entirely voluntary, allowing Vua Thợ to provide suitable products/services for users. Vua Thợ processes users' personal data for appropriate purposes as agreed in the contract, complying with legal requirements or other purposes stated in the personal data protection policy below. In case users cannot provide the necessary personal data for Vua Thợ to provide products and/or services, unfortunately, we will also not be able to provide those products and/or services to users.

Section A – Types of Personal Data We Will Collect and Process

To help us answer users' inquiries and/or provide general products and services, we may need and/or be required to process users' personal data, including but not limited to:

• Personal Information: Information that identifies users, including but not limited to name, ID card number, birth certificate number, passport number, nationality, address, phone number, fax number, bank information, credit card information, ethnicity, gender, date of birth, marital status, residence status, educational background, financial status, personal preferences, users' email address, occupation, users' identification on Vua Thợ's Website/Application, information about users on Vua Thợ's Website/Application, users' field of work, any information that users have provided to Vua Thợ in registration forms, membership applications, or any similar forms and/or any information about users that has been or will be collected, stored, used, and processed by Vua Thợ over time, including sensitive personal data such as health data, religion, or similar beliefs.
• Information about our business relationship with users helps us conduct business with users, such as types of services we provide that may interest users and information that helps us adjust services to suit users.
• Information that users provide when registering for any of our products and services, including users' opinions through feedback or surveys.
• Electronic data or other information related to users such as IP addresses, cookies, activity logs, online identities, and users' location information through users' use of our products and services or as part of the process of sending to users. For example, users' call history to our client service hotline and, if users contact us through our online services or through our website/application, details such as mobile phone location data, IP addresses, and MAC addresses. Additionally, we will record information about users when users start entering information into the contact form on Vua Thợ's websites and send users' progress or completion status when necessary.

Providing users' Personal Data is entirely voluntary. However, if users do not provide Vua Thợ with their Personal Data, Vua Thợ will not be able to process users' Personal Data for the Purposes and Additional Purposes as described below.

If users are a partner, providing users' Personal Data is mandatory, and not providing users' Personal Data may constitute a violation of the law or legal regulations and may prevent Vua Thợ from collaborating with users to provide services or products or to make payments to users for the products or services that users provide.

Some Personal Data that we collect and process may be basic or sensitive personal data as required by law or natural characteristics. Users can learn more about how we process sensitive personal data in Section E

Part B – How we collect personal data of Users

- Directly from Users through various means:

• When Users submit registration requests or any other forms related to Vua Thợ's services.
• When Users interact with Vua Thợ's User Service representatives, such as through phone calls, letters, face-to-face meetings, emails, or interactions on social media or any other communication channels.
• When Users use Vua Thợ's Website/Application.
• When Users update, supplement, or adjust their personal information, Vua Thợ will also collect that information.
• When Users access our electronic news pages or Vua Thợ's social media platforms and/or download our mobile device applications, which may leave the device's IP address or data collected through cookies.
• When Users are contacted and respond to marketing representatives and User Service employees of Vua Thợ or participate in contests organized by Vua Thợ; from various entities or units under Vua Thợ; surveys, promotional programs.
• When Users provide their personal information to Vua Thợ for any other reason, including when Users register for a free trial of any services or express interest in any of Vua Thợ's services.

- From third parties if they have been consented to, transferred, or chosen by Users to disclose. By agreeing for third-party controllers and/or processors of personal data related to Users to transfer Personal Data to Vua Thợ, Vua Thợ understands that Users have agreed to this Policy, and in the case of receiving data from those third parties, Vua Thợ will treat client data in accordance with the provisions of this Policy.

Part C – Purposes for which we process personal data of Users

1. For Users who are clients of services provided by Vua Thợ.

• To fulfill Vua Thợ's obligations under any agreements signed with Users.
• To provide Users with any requested services.
• To process Users' registrations and provide services to Users.
• When Users request to download and use Vua Thợ's application ('Application'), or to process Users' requests.
• Marketing activities, advertising, notifying Users about services, events, programs, or changes in Vua Thợ's policies and principles.
• To process, manage, or verify Users' subscriptions to Vua Thợ and provide benefits to subscribers.
• To confirm Users' orders and process payments related to any products or services requested by clients.
• To develop, enhance, and provide services to meet Users' needs.
• Collecting and demanding amounts owed by Users, investigating, analyzing, and resolving Users' requests during Vua Thợ's service to Users.
• To communicate (including sending Users management information and other information related to any contracts or accounts Users may have with Vua Thợ), to provide technical support related to Vua Thợ's Website and applications, or future changes to this Policy; to provide Users with access to content on the Website or application or Vua Thợ's social media platforms, to perform other User requests.
• Statistics, reconciliation, processing, and database management.
• Carrying out reports and explanations as required by current laws.
• At the request of competent state authorities.
• Other cases as prescribed by current laws.

For Users who are direct partners providing services to Vua Thợ's Clients:

• To serve the purpose of collaboration with Users to provide services or products.
• For identification and authentication purposes.
• To create conditions or allow any checks that Vua Thợ may require to collaborate with Users.
• When Users request to download and use the Vua Thợ application ('Application'), or to process User requests.
• Profile assessment, contract signing.
• Collecting, demanding User's amounts, debts, analyzing, aggregating, processing, and resolving User requests during the execution of contracts, cooperation agreements signed with Vua Thợ (such as contract amendment requests).
• To process payments related to any services that Users provide to Vua Thợ's Clients.
• Managing, monitoring, and evaluating the quality of User activities.
• Marketing activities, advertising, notifying Users about programs, services, events, or changes to Vua Thợ's policies and principles.
• To communicate (including sending Users management information and other information about any insurance agency contracts or accounts that Users may have with Vua Thợ), to provide technical support related to Vua Thợ's website and applications, or future changes to this Policy, to provide Vua Thợ with access rights to content on the website or application or Vua Thợ's social media platforms, and to perform other client requests.
• Statistics, reconciliation, data processing, and management.
• Conducting reports, explanations as required by current law.
• At the request of competent state authorities.
• Other cases as prescribed by current law.

3. Users are other partners

Depending on the specific services that Vua Thợ and partners have signed or intend to sign, Vua Thợ commits to only collect personal data of partners or personal data provided by partners, within the scope and specific purposes to serve Vua Thợ's business activities (such as sending marketing information, introducing products, promotions, client care, or survey activities), executing contracts, complying with Vua Thợ's regulations and regulations. For example, we will collect contact information to allow communication with partners (such as full name, username, email address, phone number); or information about Vua Thợ's business relationship with partners, transaction information on how they interact (such as account information, transaction information).

Part D - Who we share User's personal data with and why

We do not share personal data about or related to Users with entities, organizations, and individuals outside of Vua Thợ except in the following cases:

1. With the consent of the User, we will share User's data with companies, organizations, or individuals outside of the User when we have User's consent to do so.

2. Sharing personal data as part of providing products and services to Users and managing and/or operating products and services and/or to fulfill any of the purposes stated in Part C of this Policy related to the use of User's personal data, or if the law permits and if the disclosure is necessary to meet the requirements for the following parties:

User's Personal Data may be transferred, accessed, or disclosed to third parties to serve the Purposes in this Policy. In addition, Vua Thợ may work with other companies, service providers, or individuals to act on behalf of Vua Thợ to perform functions, and therefore may provide access to or disclose User's Personal Data to such service providers or third parties. Third parties include, but are not limited to Vua Thợ's partners, including Vua Thợ's partners in certain events, programs, and activities; Event organizing companies and event sponsors; Market research companies; Service providers, including information technology (IT) service providers for infrastructure, software, and development work; External consultants and auditors, including legal advisors, financial advisors, and consultants; Other organizations within Vua Thợ; and Government agencies to enforce legal regulations. Personal Data may also be shared in connection with business transactions, such as branch sales or departments, mergers, consolidations, or asset sales, or in rare cases, business dissolution.

Vua Thợ commits to sharing or jointly processing personal data only when necessary to fulfill the Processing Purposes specified in this Policy or as required by applicable law. Organizations and individuals receiving User's personal data must comply with the contents specified in this Policy and relevant data protection laws.

Although Vua Thợ will make every effort to ensure that User's information is anonymized/encrypted, it is not possible to completely eliminate the risk that this data may be disclosed in unforeseeable circumstances.

3. For legal reasons, Vua Thợ may share User's personal data with entities, organizations, or individuals outside of Vua Thợ if we have grounds to reasonably believe that accessing, using, preserving, or disclosing that information is reasonably necessary to:

• Comply with any applicable laws, regulations, current legal procedures or enforceable requests from competent state authorities, including investigating potential violations.
• Detect, prevent, or otherwise address issues related to fraud, abuse, security, or technical issues.
• Protect the rights, property, or safety of Users and Vua Thợ.

Part E - Processing sensitive personal data of Users

In some cases or for certain products or services, we may need to process sensitive personal data of Users, such as information related to health, genetics, biometric identification, and gender orientation. This is personal data associated with privacy rights, and when violated, it directly affects the legitimate rights and interests of Users. Therefore, we only process this personal data with User's consent and/or strict compliance with applicable laws in force.

Part F - Processing personal data of minors and other individuals

If Users are parents or legal guardians, please do not allow minors (under 18 (eighteen) years old) under the guardianship of Users to send Personal Data to Vua Thợ. In such cases where such Personal Data is provided to Vua Thợ, by doing so Users consent to the processing of the Personal Data of minors and Users accept and agree to be bound by this Policy and be responsible for the actions of minors.

In some cases, Users may have provided Personal Data related to other individuals (such as spouses, family members, or friends of Users), and in those cases, Users represent and warrant that Users have been authorized to provide their Personal Data to Vua Thợ and Users have obtained their consent to the processing and use of their Personal Data as described in this Policy.

Before processing personal data related to data subjects who are missing, deceased, we will need the consent of the spouse, adult child, or legal representatives of that person, unless otherwise provided by law, such as cases where we are allowed to process personal data without the consent of the data subject.

Part G - Processing data when accessing the website

1. Data processing tools

Data processing tools are the unique detection tools on the user's computer or on other devices through a website's server, containing information that can later be read from the server provided to the user by this tool.

King Tool can use various processing tools on websites, applications, and different tools managed by us. The information collected includes but is not limited to the user's IP address, domain name, web browsing software, types, and configurations of the user's web browsing tool, language settings, geographical location, operating system, referring websites, viewed websites and content, along with the access time... for statistics, analysis, aggregation, improving the quality of websites, applications, and serving advanced quality service activities provided to users.

These data processing tools can also make our websites, applications, and tools record user access and preferences, while adjusting websites, applications, and tools to meet user needs. Data processing tools for advertising purposes allow us to provide more relevant advertising models on our websites, applications, and tools, such as selecting advertising models based on user interests or blocking advertising models with continuously sent content to users.

Most web browsing tools are designed first to receive user consent for data processing, and users can temporarily block or refuse or set their web browsing tools. However, users may not enjoy all the rights from our websites, applications, or tools, and some functions may not work correctly.

In addition, we may apply automated personal data processing methods through algorithms to process user data.

2. External Connections

If any part of the websites, applications, or tools managed by us contains links to other websites, those pages may not be subject to this policy. Users should check the privacy provisions on those websites to understand their policies when collecting, using, transferring, and disclosing personal data.

Part H – Rights and Obligations of Users

Personal data protection laws allow users to exercise certain rights and corresponding obligations towards us when we process their personal data.

Users have the following rights:

• To know how we process their personal data.
• To consent or not consent to allow us to process their personal data.
• To access, view, edit, or request us to edit their personal data.
• To withdraw their consent.
• Or request us to delete their personal data.
• To request us to limit the processing of their personal data.
• To request a free copy of their personal data (we may charge the user's request if there is no clear basis or it is abused excessively).
• To object to us processing their personal data to prevent or limit the disclosure of personal data or use it for marketing, product introduction, advertising, and promotion purposes.
• To request compensation for damages as provided by law in case of violations of the user's personal data protection regulations, except in cases of other agreements between the parties.

To enforce their rights on a legal basis or to explain these rights, users may contact us in theContact

• We reserve the right to request additional appropriate documents, certificates to help us identify and screen, verify the legitimacy, validity of user requests to us. After verification, we will process user requests within the time frame prescribed by law.
• We have the right to refuse user requests in cases where the request violates current legal regulations. If the request does not comply with the regulations related to personal data processing or may significantly affect the rights and freedoms of others, we may refuse the requested action. This is to ensure that we do not violate legal regulations and comply with personal data protection regulations.
• We have the right to refuse requests In cases where requests for personal data are commercially confidential, commercial confidential information is protected to ensure that no disclosure of important information to competing partners or third parties without access rights occurs.
• If the request affects the rights and freedoms of others or is groundless or excessive, we have the right to refuse the requested action.
• In certain situations, we may refuse user requests if we cannot confirm the user's identity or if we receive multiple requests for the same type of information.

In all cases mentioned above, King Tool will notify the user of the reasons for not being able to fulfill the user's request.

If users do not want their personal data to be collected through cookies on the website, users can disable cookies by adjusting their internet browser settings to disable, block, or turn off cookies, by clearing their browsing history or clearing the cache memory from their internet browser.

Users have the following legal obligations:

• To protect their personal data; proactively apply measures to protect their personal data during the use of King Tool services.
• Timely notify King Tool when they discover errors, misunderstandings about their personal data or suspect that their personal data is being violated.
• Respect and protect the personal data of others.
• Provide complete and accurate personal data when consenting to allow us to process personal data.
• Take responsibility for the information, data, and approvals they create and provide on the network environment; take responsibility in case personal data is leaked or violated due to their mistakes.
• Regularly update the Regulations, Policies of King Tool in each period as notified to users or posted on websites and/or other transaction channels of King Tool in each period.
• Other obligations as provided by relevant legal regulations

Part I - Storage and Destruction of Personal Data

The personal data of users that we store will be secured by implementing reasonable measures. Within the legal framework, we may store user personal data for the necessary period to fulfill the specific purposes of processing personal data as stated in this Privacy Policy. We may have to store user personal data longer based on the requirements of the law in effect at the time, such as tax laws, anti-money laundering laws, or to resolve disputes, legal issues, if any. We will also keep user personal data for the time necessary to achieve our advertising goals unless the user requests the deletion of their personal data. (Part K).

We will stop storing documents containing personal data about or related to you as soon as we realize that the purpose for which we collect the data no longer meets our requirements, and we no longer need that data for business or legal purposes. Additionally, we may also anonymize personal data so that it is no longer associated with you.

Part K - Commitment to delete User's personal data.

When deleting an application account at the request of the user, Vua Thợ will delete user data associated with that application account. We will only retain certain data related to transactions if necessary for legitimate reasons such as:

• Compliance with any applicable laws, regulations, current legal procedures, or enforceable requests from competent state authorities, including investigating potential violations.
• Detection and prevention of fraud, misconduct, security, or technical issues.
• Protecting the rights, property, or safety of the user and Vua Thợ.

Part L – Consequences, unforeseen damages may occur

As mentioned in Section EUsers have certain rights as defined by the law, and we may need a reasonable time (depending on the complexity and impact of the user's request on our relationship with the user) to process the user's request and/or to inform the user of the consequences, unforeseen damages that may occur if the user's request is fulfilled.

We hope users will note that:

• Depending on the nature and scope of the user's request, we may not be able to continue providing services to the user, and, as required by law in each case, we will also notify the user before completing the processing of the user's request.
• Or, in cases where we cannot withdraw the user's consent while Vua Thợ is performing obligations under the contract between Vua Thợ and the user, or when it is necessary to immediately process personal data related to protect the life, health of the data subject or others as prescribed by law.

Part M - Commitment to the security of user's personal data

User's personal data on Vua Thợ's Application and Website are absolutely committed to security under Vua Thợ's personal information protection policy. The collection and use of user information are only carried out with the user's consent unless otherwise provided by law. Vua Thợ commits that:

• Vua Thợ only retains personal data when necessary for legal and business purposes. Vua Thợ commits to secure the user's personal data as well as comply with the requirements for personal data security under Vietnamese Law at each point in time. During the retention of that personal data, we will implement appropriate protection methods as required by current laws to prevent unauthorized access, collection, use, disclosure, copying, alteration, destruction, or similar risks.
• Except for specific cases listed in this Privacy Policy, Vua Thợ will not disclose any user's personal data to third parties without the user's consent or in situations as provided by law.
• Vua Thợ will take necessary steps to ensure the safe storage of user's personal data provided to the Company.
• In case the server storing information is attacked by hackers leading to the loss of user's personal data, Vua Thợ will be responsible for notifying the competent authorities for timely investigation and inform the user.
• Vua Thợ requires users, when registering/purchasing as a Member, to provide full relevant personal information such as: full name, contact address, email address, identity card number, phone number, account number, payment card number..., and take responsibility for the accuracy, legality, and updating of such information. We will not be responsible for, and will not resolve any complaints related to user's rights if it is found that the personal data provided by the user is inaccurate.

Part N: Mechanism for resolving complaints, disputes:

When complaints or disputes related to user's personal information arise, Vua Thợ values negotiation and reconciliation solutions between parties to maintain trust in Vua Thợ's service quality and follows these steps:

Step 1: Users file complaints about incidents related to their personal data to Vua Thợ by contacting the address below.

Step 2: Vua Thợ's Client Care department will receive user complaints, depending on the nature and extent of the complaint, Vua Thợ will have specific measures to assist users in resolving the dispute and provide a response to the user within 15 working days.

In cases where the matter is beyond Vua Thợ's capability and jurisdiction to resolve, Vua Thợ will request the user to submit the matter to the competent state authority for resolution under the law.

Part O: Contact us

In case users have any questions or concerns related to the Personal Data Privacy Policy or if users wish to exercise their rights inPart H , users can contact us in various ways.

• Call our hotline: 38 786 688
• Send an email to us at: social@vuatho.com
• Or contact us directly at our office: 35, An Khánh Ward, thành phố Thủ Đức, Ho Chi Minh City, Vietnam.
• Headquarters: 35, An Khánh Ward, thành phố Thủ Đức, Ho Chi Minh City, Vietnam.
• Phone:  38 786 688
• If users wish to stop receiving advertising from Vua Thợ, please send an email to: social@vuatho.com