PERSONAL DATA PROTECTION POLICY

AdFlex Vietnam Joint Stock Company ("AdFlex") values and respects the privacy, confidentiality and security of personal information in accordance with the laws of Vietnam. AdFlex created this Personal Data Protection Policy to demonstrate our commitment to the right to privacy of Personal Data to Users of this website and AdFlex Partners.

I. INTERPRETATION OF WORDS

Personal Data means information in the form of symbols, scripts, digits, images, sounds or the like in the electronic environment that is associated with a specific person or helps identify a specific person. Personal data includes basic personal data and sensitive personal data.
Personal Data Processing means one or more activities affecting personal data, such as: collection, recording, analysis, confirmation, storage, correction, publicity, combination, access, retrieval, withdrawal, encryption, decryption, copying, sharing, transmission, provision, transfer, etc deletion, destruction of personal data or other related actions.
Data Subject means an individual reflected by personal data.
Personal Data Protection Measures means all measures, means, tools and means to best protect personal data of data subjects, and ensure compliance with relevant Laws.
Relevant Legal Provisions are Decree 13/2023/ND-CP and its amendments, and other legal documents related to the Processing of Personal Data and the protection of Personal Data.
Data Controller: means an organization or individual that decides on the purposes and means of processing Personal Data.
Data Processor: means an organisation or individual that processes Personal Data on behalf of Data Controller, through a contract or agreement with Data Controller.
Data Controller and Processor: means an organization or individual that simultaneously decides on the purpose, means and directly processes personal data.
Permitted Third Parties: means organizations and individuals other than Data Subjects, Data Controllers, Data Processors, Data Controllers and Processors permitted to process Personal Data, including but not limited to third parties Processing Personal Data on behalf of Data Processor, third parties are permitted to Process Personal Data with the Data Subject's consent in this Personal Data Protection Policy and agreements and documents with Data Subjects.
Personal Data Protection Policy: is an agreement between AdFlex and the Data Subject/Partner explaining AdFlex's policies and regulations related to the protection and Processing of Personal Data.

II. EFFECT OF THE PERSONAL DATA PROTECTION POLICY

By registering, registering, using, using the Products and Services, entering into contracts and/or providing Personal Data to AdFlex on any platform and/or in any manner that permits AdFlex to process the Personal Data, the Data Subject/Partner has read, understand, accept in its entirety and without attaching any conditions to the contents mentioned in this Personal Data Protection Policy and changes (if any) from time to time.
This Personal Data Protection Policy is an integral part and should be read and understood in accordance with the contracts, agreements, terms, conditions and other documents established between the Data Subject/Partner and AdFlex.
All rights and obligations of the Parties in this Personal Data Protection Policy shall not supersede, terminate or change, but shall accrue to the rights and obligations that AdFlex and the Data Subject/Partner have in any agreed upon document.

III. PRINCIPLES OF PROCESSING PERSONAL DATA

AdFlex is committed to the following principles when Processing Personal Data:

AdFlex processes and protects Personal Data in accordance with the laws of Vietnam; fully comply with this Personal Data Protection Policy and other contracts, agreements, terms, conditions, documents established with the Data Subject/Partner.
AdFlex collects Personal Data for specific, explicit and legitimate purposes, within the scope of the purposes stated in this Personal Data Protection Policy, other contracts, agreements, terms, conditions, documents established with Data Subjects/Partners and in accordance with Vietnamese laws.
Personal Data is updated and supplemented in accordance with the purposes of processing.

IV. PURPOSE OF PROCESSING PERSONAL DATA

AdFlex may Process Personal Data for one or more of the following purposes, including but not limited to:

Verify the accuracy and completeness of the information provided by the Data Subject/Partner; identify or authenticate the identity of the Data Subject/Partner and carry out the Data Subject/Partner authentication process;
Process the Data Subject/Partner's registration of any products and services proposed or provided by AdFlex;
To fulfill the obligation to reconcile and pay with the Data Subject/Partner;
Provide products and services proposed or provided by AdFlex or its affiliates;
Contact the Data Subject/Partner to exchange information, deliver invoices, statements, reports or other relevant documents;
Notify Data Subjects/Partners of information about benefits, changes in features of products and services;
Manage and evaluate business activities including designing, improving and improving the quality of AdFlex products and services or carrying out marketing communications;
To serve internal management purposes such as auditing, data analysis, database storage; evaluate and analyze AdFlex's markets, partners, services;
To AdFlex's suppliers/service providers/partners to perform services for Data Subjects/Partners and/or AdFlex;
For the purpose of detection, prevention and prosecution of crimes;
To assist AdFlex in complying with its obligations under law;
Send to Data Subjects/Partners notices, newsletters, updates, promotional materials, special privileges from AdFlex, its partners, sponsors and advertisers;
Notify and send invitations to Data Subjects/Partners about events; activities hosted by AdFlex, its partners, sponsors or advertisers;
Other contents that AdFlex is permitted to use Personal Data and other relevant information not contrary to the provisions of law.

For the avoidance of doubt, by accepting this Personal Data Protection Policy, the Data Subject/Partner agrees that AdFlex is entitled to process Personal Data (including updated Personal Data in the future) for all the purposes set out above AdFlex will require consent from the Data Subject/Partner prior to using the Data Individuals of Data Subjects/Partners for purposes other than those stated in the Personal Data Protection Policy.

V. HOW PERSONAL DATA IS PROCESSED

Depending on the purpose of Personal Data Processing, AdFlex or AdFlex's or Authorised Third Party Data Processors may adopt appropriate processing practices including but not limited to automated, manual or other Personal Data Processing in accordance with the law and AdFlex from time to time.

VI. RETENTION OF PERSONAL DATA

Personal data of Data Subjects/Partners stored by AdFlex will be kept confidential. AdFlex will take reasonable measures to protect the Personal Data Subject/Partner's personal data.
AdFlex will apply data security standards on the basis of ensuring compliance with applicable laws.
AdFlex retains Personal Data of the Data Subject/Partner for as long as necessary to fulfil the purposes under this Personal Data Protection Policy, unless the retention period of Personal Data is longer than required or permitted by applicable laws.

VII. DISCLAIMER

AdFlex does not warrant that AdFlex and any products or services provided by AdFlex will meet the requirements of the Data Subject/Partner, nor does it warrant that the operation of AdFlex will be uninterrupted, free from delays, order rejections, errors, etc loss or destruction of information or errors caused by viruses, third parties or other force majeure risks. AdFlex shall be exempt from liability for matters related to the above incident (if any). AdFlex is not responsible for the authenticity of information provided by the Data Subject/Partner or the transaction between the Data Subject/Partner and AdFlex's partner or the Data Subject/Partner's violation of law.

VIII. RIGHTS AND OBLIGATIONS OF DATA SUBJECTS/PARTNERS IN RELATION TO PERSONAL DATA PROVIDED TO ADFLEX

Data Subjects/Partners have the following rights: (i) Right to know; (ii) Right to consent; (iii) Right of access; (iv) The right to withdraw consent; (v) Right to erasure; (vi) The right to restrict data processing; (vii) Right to data disclosure; (viii) Right to object to processing; (ix) The right to complain, denounce or initiate lawsuits; (x) The right to claim damages; (xi) The right to self-protection and other related rights as prescribed by law.
To the extent permitted by law, the Data Subject/Partner may exercise his/her rights by contacting AdFlex using the information provided.
AdFlex shall, at reasonable endeavours, honour a lawful and valid request from the Data Subject/Partner within the statutory period of receipt of the complete and valid request from the Data Subject/Partner, subject to AdFlex's right to invoke any legal exemptions and/or exceptions.
In case the Data Subject/Partner withdraws his/her consent, requests deletion and/or exercises other relevant rights with respect to any or all personal data of the Data Subject/Partner, and depending on the nature of the Data Subject/Partner's request, AdFlex may consider and decide not to continue providing AdFlex products and services to Data Subjects/Partners. Actions performed by the Data Subject/Partner in accordance with this provision shall be considered as unilateral termination on the part of the Data Subject/Partner for any relationship between the Data Subject/Partner and AdFlex, and may completely result in a breach of obligations or contractual commitments between the Data Subject/Partner Partner with AdFlex, and AdFlex reserves AdFlex's legitimate rights and remedies in such circumstances. Accordingly, AdFlex shall not be liable to the Data Subject/Partner for any losses incurred, and AdFlex's legal rights shall be expressly reserved with respect to such limitation, restriction, suspension, cancellation, suppression, or prohibition.
For security purposes, the Data Subject/Partner may need to make his/her request in writing or use another method to prove and authenticate the identity of the Data Subject/Partner. AdFlex may require the Data Subject/Partner to verify his/her identity before processing the Data Subject/Partner's request.

IX. AMENDMENTS

The terms and conditions of this Personal Data Protection Policy may be amended, updated or amended from time to time and will be posted on AdFlex's website at: https://adflex.vn/ and/or on other AdFlex official means and/or notified to Data Subjects/Partners through AdFlex's appropriate means.

X. CONTACT INFORMATION PROCESSING OF PERSONAL DATA

In case the Data Subject/Partner has any questions regarding the Personal Data Protection Policy or matters related to the Data Subject's rights or the processing of personal data, the Data Subject/Partner please contact us:

• Website: https://adflex.vn/

• Text: directly to the account manager for support.

• AdFlex Office: 2nd floor, A1 – A3, Ecolife Capitol Building, 58 To Huu, Me Tri Ward, Nam Tu Liem District, Hanoi, Vietnam.