Personal Data Collection and Processing Policy (“Policy”) is implemented by Duy Anh Fashion and Cosmetics Joint Stock Company; Enterprise Registration Certificate/Tax Code No. 0304130177; Head office address: 3rd Floor, Centec Tower, 72–74 Nguyen Thi Minh Khai Street, Xuan Hoa Ward, Ho Chi Minh City, Vietnam (“DAFC” or “Company”), describing activities related to the Processing of Customers’ Personal Data.
This Policy forms an integral part of the contracts, agreements, terms, and conditions governing the relationship between DAFC and Customers.
Article 1: SCOPE AND APPLICABILITY
This Policy monitors how DAFC processes the Personal Data of Customers and/or individuals who jointly use DAFC’s products/services with the Customer when using products/services provided by DAFC and/or when interacting with the Website. For clarity, this Policy applies only to individual Customers. DAFC encourages Customers to read this Policy carefully and regularly check DAFC’s Website for any updates that DAFC may make in accordance with the terms of this Policy.
Article 2: DEFINITIONS
- Customer: An individual who accesses, explores, registers, purchases, uses products or services, or is otherwise involved in the operational process of providing products and services by DAFC.
- DAFC or Company: Duy Anh Fashion and Cosmetics Joint Stock Company, Enterprise Registration Certificate/Tax Code No. 0304130177, headquartered at 3rd Floor, Centec Tower, 72–74 Nguyen Thi Minh Khai Street, Xuan Hoa Ward, Ho Chi Minh City, Vietnam.
- Personal Data or PD: Information in the form of symbols, letters, numbers, images, sounds, or similar forms in an electronic environment associated with a specific individual or enabling the identification of a specific individual. Personal Data includes Basic Personal Data and Sensitive Personal Data.
Basic Personal Data includes:
- Full name, birth name, other names (if any);
- Date of birth, date of death or disappearance;
- Gender;
- Place of birth, place of birth registration, permanent residence, temporary residence, current address, hometown, contact address;
- Nationality;
- Individual’s image;
- Phone number, ID card number, personal identification number, passport number, driver’s license number, vehicle license plate number, personal tax code, social insurance number, health insurance card number;
- Marital status;
- Family relationship information (parents, children);
- Personal account information; Personal Data reflecting activities or activity history in cyberspace;
- Other information associated with or identifying a specific individual that does not fall under Sensitive Personal Data;
- Other data as prescribed by current laws.
Sensitive Personal Data includes:
- Political opinions, religious beliefs.
- Health status and private life recorded in medical records, excluding blood group information.
- Information related to racial or ethnic origin.
- Genetic information inherited or acquired by the individual.
- Information on physical attributes, unique biological characteristics.
- Information on sexual life, sexual orientation.
- Criminal data, criminal acts collected and stored by law enforcement agencies.
- Customer information of credit institutions, foreign bank branches, intermediary payment service providers, and other permitted organizations, including customer identification information as prescribed by law, account information, deposit information, asset information, transaction information, information on organizations or individuals acting as guarantors.
- Location data of individuals determined through positioning services.
- Other Personal Data defined by law as special and requiring necessary security measures.
Personal Data Protection: Activities to prevent, detect, stop, and handle violations related to Personal Data in accordance with the law.
Personal Data Processing: One or more activities impacting Personal Data, such as: collection, recording, analysis, verification, storage, modification, disclosure, combination, access, retrieval, recovery, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction, or other related actions.
Company’s Partner: An organization or individual providing products, services, and/or operations for DAFC under contracts, agreements, or other legally equivalent forms.
Third Party: Any organization or individual other than DAFC and the Customer as defined in this Policy. For clarity, any terms not explained in this section shall be understood and applied according to current Vietnamese law.
DAFC Transaction Channels: Including Websites, retail channels at DAFC stores, electronic transaction channels, and/or other channels for providing products/services or serving the needs of DAFC and Customers.
Article 3. PURPOSES OF PROCESSING YOUR PERSONAL DATA
The Customer agrees to allow DAFC to process their Personal Data for one or more of the following purposes:
- Provide products or services or assist the Customer in using products/services of the Company and/or the Company’s Partners through cooperation agreements requested by the Customer;
- Advise, evaluate, handle, respond to, or resolve inquiries, requests, feedback, questions, instructions, or complaints from the Customer; as well as perform after-sales activities and customer care;
- Adjust, update, secure, and improve products, services, applications, and devices provided by DAFC to the Customer;
- Verify identity and ensure the security of the Customer’s personal information;
- Fulfill service requests and support needs of the Customer;
- Notify the Customer of changes to policies, promotions of products/services provided by the Company; exchange information, including but not limited to promotional services, advertising campaigns related to products/services via methods such as phone calls, electronic communication channels like email, fax, etc.
- Measure, analyze internal data, and perform other processing to improve and enhance the quality of the Company’s products/services or conduct marketing communication activities;
- Organize market research and public opinion surveys to improve product/service quality or develop new products/services to better meet Customer needs;
- Prevent and combat fraud, identity theft, and other illegal activities;
- Establish, exercise, or protect DAFC’s or the Customer’s legal rights. These purposes may include data exchange with other companies and organizations to prevent and detect fraud and minimize credit risks;
- Comply with applicable laws, relevant industry standards, and other current Company policies.
- Any other purpose specific to the Company’s operational activities;
- Provide information to IPPG Group and affiliated companies to achieve the above purposes, provided that the recipient is bound by strict confidentiality terms equivalent to those in this document;
- Any other purpose notified to the Customer at the time of collecting Personal Data or before commencing related processing, or as otherwise required or permitted by applicable law;
- Maintain, check, and/or operate any system or platform necessary to provide any Company product/service or related to websites or mobile applications provided by the Company to the Customer;
- Verify the Customer’s identity to process orders placed through the Company’s sales platforms such as websites or mobile applications;
- Market, promote, improve, and enhance the provision of products/services by the Company and optimize the Customer experience related to products/services through the collection and processing of Customer data;
- Share with organizations, affiliates, and the Company’s Partners, including entities within IPPG Group, to enable them to conduct market research, planning, customer surveys, trend analysis, and/or other related data analysis to better tailor offers, promotions, and/or other direct marketing activities for the Company;
- Provide additional services or value-added services;
- Manage and deliver benefits for loyal customers, rewards, promotions, contests, lucky draws, and other related benefits;
- Notify the Customer about new products/services offered by the Company or any organization, affiliate, and the Company’s Partners.
- Any other purpose that (i) is permitted or required by applicable laws, industry rules, or market regulations; (ii) is necessary, supplementary, or consequential to the above purposes; or (iii) the Company deems necessary to comply with applicable personal data protection laws.
DAFC will seek the Customer’s consent before using their Personal Data for any purpose other than those stated above, either at the time of collection or before commencing related processing, or as otherwise required or permitted by applicable law.
Article 4: CONFIDENTIALITY OF CUSTOMERS’ PERSONAL DATA
Privacy Principles
- The Customer’s Personal Data is committed to being protected in accordance with DAFC’s regulations and applicable laws. The processing of each Customer’s Personal Data will only be carried out with the Customer’s consent, except where otherwise required by law.
DAFC does not use, transfer, provide, or share the Customer’s Personal Data with any Third Party without the Customer’s consent, except where otherwise required by law.
DAFC will comply with other Personal Data protection principles as prescribed by applicable laws. - Potential Unintended Consequences or Damages
DAFC employs various information security technologies to protect the Customer’s Personal Data from unauthorized access, use, or sharing. However, no data can be guaranteed to be 100% secure. Therefore, DAFC commits to protecting the Customer’s Personal Data to the maximum extent possible. Some potential unintended consequences or damages may include, but are not limited to: - Hardware or software errors during data processing causing data loss;
Security vulnerabilities beyond DAFC’s control, such as system breaches by hackers leading to data leaks;
Customers accidentally exposing Personal Data due to carelessness or being tricked into accessing malicious websites/downloading harmful applications, etc. - DAFC advises Customers to keep login credentials and OTP codes confidential and not share them with anyone.
- Customers should safeguard their electronic devices during use and lock, log out, or exit their accounts on DAFC’s website or application when not in use.
Article 5: TYPES OF PERSONAL DATA PROCESSED BY DAFC
To enable DAFC to provide products and services to Customers and/or handle Customer requests, DAFC may need to and/or be required to collect Personal Data. The Customer’s Personal Data includes the following information:
- Customer’s Basic Personal Data;
- Data related to Websites or Applications: technical data (as mentioned above, including device type, operating system, browser type, browser settings, IP address, language settings, date and time of connection to the Website, application usage statistics, application settings, date and time of connection to the application, location data, and other technical communication information); secure login details; usage data;
- Marketing Data: advertising interests; cookie data; clickstream data; browsing history; responses to direct marketing; and opt-out preferences for direct marketing.
| Basic personal data (pursuant to Clause 3, Article 2 of the Government’s Decree No. 13/2023/ND-CP dated April 17, 2023 on personal data protection; included X in the prescribed data type) | |||
| Last name, middle name, and birth name | X | Nationality | X |
| Other names (if any) | Images | X | |
| Date of birth | X | Phone Number | X |
| Date, month, year of death or disappearance | Identity card number | X | |
| Gender | X | Personal Identification Number | X |
| Birthplace | Passport number | ||
| Place of birth registration | Driver’s License Number | ||
| Permanent Residence | License plate number | ||
| Temporary Shelter | Personal tax identification number | ||
| Current Residence | X | Social insurance number | |
| Hometown | Health insurance card number | ||
| Contact Us | X | Marital Status | |
| Information about family relationships (parents, children) | Information about an individual’s digital account | X | |
| Personal data reflects cyber activity | X | History of operations in cyberspace | X |
| Other information associated with a specific person or helping to identify a specific person not specified in Clause 4 of this Article | |||
Article 6: DATA COLLECTING METHODS
DAFC collects Personal Data from Customers through the following methods:
Directly from Customers via various means:
- When the Customer submits a registration request or fills out any other form related to DAFC’s products and services or those of the Company’s Partners;
- When the Customer interacts with DAFC’s customer service staff, such as through phone calls, correspondence, face-to-face meetings, emails, or social media interactions;
- When the Customer uses certain DAFC services or accesses platforms operated by the Company, such as websites and applications, including creating online accounts with DAFC; CCTV recordings;
- When the Customer responds to marketing representatives or DAFC’s customer service staff;
- When the Customer provides personal information to the Company for any reason, including registering for free trials or expressing interest in any of the Company’s products or services;
- When the Customer purchases or uses services from Third Parties through DAFC or at DAFC’s transaction points or business locations;
- The Company may also collect Personal Data from other lawful sources.
From Third Parties:
If the Customer interacts with Third-Party content or advertisements on DAFC’s Website or application, the Company may receive the Customer’s personal information from the relevant Third Party in accordance with its lawful privacy policy;
If the Customer chooses to make electronic payments directly to DAFC or through DAFC’s Website or application, DAFC may receive the Customer’s Personal Data from Third Parties such as payment service providers for that purpose;
To comply with legal obligations, DAFC may receive the Customer’s Personal Data from competent authorities.
Article 7: ORGANIZATIONS INVOLVED IN PERSONAL DATA PROCESSING
DAFC may share or jointly process Personal Data with the following organizations or individuals:
- Lien Thai Binh Duong Import-Export Co., Ltd (IPPG Group);
- The Company’s Partners;
- Branches, business units, and employees working at DAFC’s branches, business units, and agents;
- Retail stores and merchants involved in DAFC’s promotional programs;
- DAFC’s professional advisors such as auditors, lawyers, etc., as required by law;
- Courts and competent state authorities in accordance with legal requirements and/or upon lawful request.
DAFC commits that sharing or joint processing of Personal Data will only occur when necessary to fulfill the Processing Purposes stated in this Policy or as required by law. Organizations or individuals receiving Customer Personal Data must comply with this Policy and applicable laws on Personal Data Protection.
Although DAFC will make every effort to ensure Customer information is anonymized/encrypted, risks of disclosure cannot be completely excluded in force majeure situations as prescribed by law.
In cases involving other organizations mentioned above, the Customer agrees that DAFC will notify the Customer before proceeding.
Article 8: PROCESSING OF PERSONAL DATA IN SOME SPECIAL CASES
DAFC ensures that the processing of Customer Personal Data fully complies with legal requirements in the following special cases:
- CCTV recordings may be used for purposes such as:
- Quality assurance.
- Public security and workplace safety.
- Detecting and preventing suspicious, inappropriate, or unauthorized use of Company facilities, products, or services.
- Detecting and preventing criminal acts and/or investigating incidents.
- Children’s Personal Data: DAFC respects and protects children’s Personal Data. In addition to legal requirements, before processing children’s Personal Data, the Company will verify the child’s age and obtain consent from (i) the child and/or (ii) the child’s parent or legal guardian as required by law.
- Personal Data of missing or deceased individuals: In addition to complying with relevant legal provisions, DAFC must obtain consent from one of the related persons as prescribed by current law before processing such data.
Article 9: CUSTOMER RIGHTS AND OBLIGATIONS REGARDING PERSONAL DATA PROVIDED TO DAFC
Customer Rights:
- The Customer has the right to be informed about the processing of their Personal Data, except where otherwise required by law.
- The Customer has the right to consent or refuse consent for the processing of their Personal Data, except where otherwise required by law.
- The Customer has the right to access, review, edit, or request corrections to their Personal Data by submitting a written request to DAFC, except where otherwise required by law.
- The Customer has the right to withdraw their consent by submitting a written request to DAFC, except where otherwise required by law. Withdrawal of consent does not affect the legality of data processing previously consented to before withdrawal.
- The Customer has the right to delete or request deletion of their Personal Data by submitting a written request to DAFC, except where otherwise required by law.
- The Customer has the right to request restriction of processing of their Personal Data by submitting a written request to DAFC, except where otherwise required by law. DAFC will implement the restriction within 72 hours after receiving the Customer’s request for all Personal Data specified, except where otherwise required by law.
- The Customer has the right to request DAFC to provide their Personal Data by submitting a written request to DAFC, except where otherwise required by law.
- The Customer has the right to object to DAFC or any organization processing their Personal Data as specified in this Policy by submitting a written request to DAFC to prevent or limit disclosure or use of Personal Data for advertising or marketing purposes, except where otherwise required by law. DAFC will fulfill the Customer’s request within 72 hours after receiving it, except where otherwise required by law.
- The Customer has the right to file complaints, denunciations, or lawsuits in accordance with applicable laws.
- To the maximum extent permitted by law, DAFC shall be exempt from legal liability, and the Customer agrees to indemnify DAFC for any damages related to Personal Data in all cases, except where DAFC violates Personal Data protection regulations under this Policy and applicable laws. In such cases, the Customer may only claim compensation as prescribed by law.
- The Customer has the right to self-protection under the Civil Code and other relevant laws or request competent authorities or organizations to enforce civil protection measures.
- The Customer has the right to revoke all or part of their consent at any time by sending an official written notice to the Company, in compliance with applicable data protection laws. The Customer acknowledges that revoking consent may limit their access to certain services, benefits, and rights as specified in this Policy.
- Other rights as prescribed by applicable laws.
Customer Obligations
- Comply with applicable laws, regulations, and DAFC’s guidelines related to the processing of Personal Data.
- Provide complete, truthful, and accurate Personal Data and other information as requested by DAFC when registering and using DAFC’s services, and promptly update any changes to such information. DAFC will protect the Customer’s Personal
- Data based on the information provided during registration; therefore, DAFC shall not be liable for any impact or limitation of Customer rights caused by inaccurate information. If the Customer fails to notify changes, they shall bear responsibility for any risks or losses arising from errors, misuse, or fraud due to their own fault or failure to provide correct, complete, accurate, and timely updates, including financial damages and costs incurred from incorrect or inconsistent information.
- Cooperate with DAFC, competent authorities, or Third Parties in cases where issues affecting the security of Personal Data arise.
- Protect their own Personal Data; proactively apply measures to safeguard their Personal Data while using DAFC’s services; promptly notify DAFC upon detecting any errors, inaccuracies, or suspected breaches of their Personal Data.
- Assume responsibility for any information, data, or consent they create or provide online; bear responsibility if their Personal Data is leaked or compromised due to their own fault.
- Regularly update DAFC’s regulations and policies as notified or published on DAFC’s websites or other transaction channels from time to time. Follow DAFC’s instructions to clearly indicate consent or refusal regarding Personal Data processing purposes communicated by DAFC.
- Respect and protect the Personal Data of others.
- Fulfill other obligations as prescribed by applicable laws.
Article 10: DURATION OF PROCESSING AND STORAGE OF PERSONAL DATA
- Processing Period: Begins when the Customer consents to the Company processing their Personal Data or uses the Company’s products/services and continues until the Customer completely ceases using the Company’s products/services or requests deletion of Personal Data as specified below.
- Storage Period: Begins when the Customer consents to the Company processing their Personal Data or uses the Company’s products/services and continues until the Customer completely ceases using the Company’s products/services or requests deletion of Personal Data as specified below.
Cases where the Customer may request immediate deletion of Personal Data:
- Withdrawal of consent;
- Determining that the data is no longer necessary for the agreed collection purpose and accepting any potential consequences of deletion;
- Objecting to data processing and DAFC has no legitimate reason to continue processing;
- Personal Data is processed for purposes other than those consented to or in violation of legal regulations;
- Personal Data must be deleted as required by law.
Cases where DAFC may refuse deletion despite the Customer’s request:
- Any request is prohibited by law;
- Personal Data is processed by competent state authorities for official purposes as prescribed by law;
- Personal Data has been lawfully disclosed;
- Personal Data is processed for legal requirements, scientific research, or statistical purposes as prescribed by law;
- In emergencies related to national defense, security, public order, major disasters, dangerous epidemics; when there is a threat to security or defense but not at the level of declaring a state of emergency; prevention and control of riots, terrorism, crime, and legal violations;
- Responding to emergencies threatening the life, health, or safety of the Customer or other individuals.
Timeframe for deletion or destruction of Personal Data: Within 72 hours after the end of the storage period or upon the Customer’s request.
ARTICLE 11: METHODS OF DATA PROCESSING
DAFC applies one or more activities processing Personal Data, such as: data collection, recording, storage, retrieval, analysis, use, sharing, disclosure, deletion, encryption, decryption, and automated processing of Personal Data.
ARTICLE 12: COOKIES
When Customers use or access DAFC’s websites or online platforms (collectively referred to as “Websites”), DAFC may place one or more cookies on the Customer’s device. A “cookie” is a small file stored on the Customer’s device when they visit a Website, recording information about the device, browser, and, in some cases, the Customer’s preferences and browsing habits.
DAFC may use this information to:
- Recognize Customers when they return to DAFC’s Websites;
- Provide personalized services on DAFC’s Websites;
- Compile analytical data to better understand Website performance and improve DAFC’s Websites.
Customers can use their browser settings to delete or block cookies on their devices. However, if Customers choose not to accept or block cookies from DAFC’s Websites, they may not be able to fully utilize all features of DAFC’s Websites.
DAFC may process Customer Personal Data through cookie technology in accordance with this Policy. DAFC may also use remarketing techniques to deliver advertisements to individuals who have previously visited its Websites.
Where Third Parties embed content on DAFC’s Websites (e.g., social media features), those Third Parties may collect Customer Personal Data (e.g., cookie data) if the Customer chooses to interact with such content or use Third-Party services.
When you access the Rolex section on our website, you may be redirected to www.rolex.com. In such cases, the Privacy Policy and Cookie Policy of www.rolex.com will exclusively apply.
Article 13: CONTACT INFORMATION
If the Customer has any questions regarding this Policy or issues related to data subject rights or the processing of their Personal Data, they may contact DAFC through the following channels:
Address: DAFC – 3rd Floor, Centec Tower, 72–74 Nguyen Thi Minh Khai Street, Xuan Hoa Ward, Ho Chi Minh City, Vietnam
Email: nghia.nguyen@dafc.com.vn; phong.dang@dafc.com.vn
Phone: +84 28 3825 7537
Article 14: GENERAL PROVISIONS
This Policy takes effect from June 1, 2024.
The Customer understands and agrees that this Policy may be amended from time to time and updated through DAFC’s transaction channels. Any changes and their effective dates will be published on DAFC’s transaction channels. Continued use of DAFC’s services after the notification period for amendments constitutes the Customer’s acceptance of such changes.
The Customer acknowledges and agrees that this Policy also serves as the Personal Data Processing Notice as required under Decree No. 13/2023/NĐ-CP dated April 17, 2023, and may be amended from time to time. Accordingly, DAFC is not required to take any additional steps to notify the Customer of Personal Data Processing.
The Customer commits to strictly comply with this Policy. For matters not specified herein, both parties agree to follow applicable laws, guidance from competent authorities, and/or amendments to this Policy as notified by DAFC from time to time.
The Customer may encounter advertisements or other content on any Website, application, or device that may link to websites or services of partners, advertisers, sponsors, or other Third Parties. DAFC does not control the content or links appearing on Third-Party websites or services and assumes no responsibility or liability for activities conducted by such Third-Party websites or services linked to or from any DAFC Website, application, or device. These websites and services may be subject to their own privacy policies and terms of use.
This Policy is entered into in good faith between DAFC and the Customer. In the event of a dispute during implementation, the parties shall seek resolution through negotiation and mediation. If mediation fails, the dispute shall be submitted to the competent People’s Court for resolution in accordance with the law.
This Policy constitutes the entire understanding between the Customer and the Company regarding access to personal information and supersedes all prior agreements or understandings, whether written or oral. This Policy shall be binding and effective for the benefit of the parties and their respective successors and assigns.
The Customer has read, fully understood their rights and obligations, and agrees to all terms of this Policy.
ROLEX SECTION
While navigating on the Rolex section of our website, some cookies are controlled by ROLEX SA which applies the following Cookies Policy.