I. GENERAL PROVISIONS

1. Purpose:

This Privacy Policy (“Policy”) describes how Nha Be Trading Joint Stock Company collects and uses your personal information during your access to and interaction with the website www.nbtrade.com.vn operated by Nha Be Trading (collectively referred to as “Our Products”).

This Policy is designed to help you understand how we collect, use, disclose, and/or process your personal data that you have provided to us and/or that we store about you, whether currently or in the future.
By using Our Products, you acknowledge that:

• You have read, understood, and accepted the entire contents of this Policy; and
• You are fully aware of and voluntarily consent to our full authority to collect, use, disclose, and/or process your personal data as described below.

You also permit and agree that we may access, store, process, and disclose your account information and content in accordance with applicable law or upon the request of a court or competent government authority applicable to Nha Be Trading, or for legitimate reasons where Nha Be Trading believes such access, retention, or disclosure is necessary to: comply with legal proceedings; respond to requests from any government or regulatory authority; enforce the terms and conditions of Our Products or this Policy; respond to your customer service requests; or protect the rights, property, or personal safety of Nha Be Trading, our related affiliates, users, and/or the public.

2. Scope of Application:

This Policy applies independently or concurrently with any notices or documents provided at any of Nha Be Trading’s premises or locations. In the event of any inconsistency between this Policy and such documents on the same subject matter, this Policy shall prevail.

3. Subjects of Application:

This Policy applies to all customers who have used, are using, or will use Our Products. This Privacy Policy does not apply to any products, services, websites, or content provided by third parties or those governed by separate privacy policies.

4. This Privacy Policy covers the following topics:

(1) Types of personal information we collect
(2) Sources of information we collect
(3) Collection of other data
(4) Regulations on information collected by online advertisements and third parties
(5) How we use personal information
(6) Collection and use of cookies
(7) How we share personal information
(8) Location of personal information
(9) How we protect personal information
(10) Access and choices
(11) Personal information of minors
(12) Retention period of personal information
(13) Contact information, notifications, and changes
(14) Additional information for Europe

II. PRIVACY POLICY CONTENT

1. Types of Personal Information We Collect

1.1. Your personal information is collected during your interactions with Our Products. Personal data refers to any information provided to our company that can be used to identify an individual, as defined by applicable laws.

1.2. You agree not to provide any inaccurate or misleading information and to notify us of any inaccuracies or changes to your information as soon as possible.

1.3. If you do not wish to provide the aforementioned personal data, you may opt out at any time by sending a written notice following the instructions outlined in Section 13, Part II of this Policy. Please note that your refusal or withdrawal may affect your ability to use Our Products.

2. Sources of Information We Collect

2.1. Information You Provide to Us:
Nha Be Trading collects any information you provide in connection with Our Products.

2.2. Automatically Collected Information:
We automatically collect certain types of information when you interact with Our Products. In some cases, you may provide personal data of other individuals (e.g., family members, friends, or contacts). If you do, you represent and warrant that you have obtained their consent for us to process their data in accordance with this Policy.

2.3. Information from Other Sources:
We may collect information about you from other sources, including but not limited to service providers, partners, and publicly available sources.

3. Collection of Other Data

3.1. Your device may send information, including data about you, which may be recorded by a web server when you use our Products. If you are logged in, this information may be linked to your personal account. Such data may be used in anonymous statistics to help us understand how visitors use our Website.

3.2. When you view content, advertisements, or access other software on or through our Products or services, certain information may be transmitted to us.

4. Rules for Information Collected by Internet Ads and Third Parties

4.1. Our Products may include third-party advertisements and links to other websites and applications. These third-party advertising partners may collect information about you when you interact with their content, ads, or services.

4.2. Our Products may be supported by third-party analytics services that collect data and user interactions to improve customer experience.

4.3. We and third parties may offer software application downloads from time to time. These applications may have separate access and allow third parties to view your identifiable information. We may also engage in co-marketing or other relationships to provide e-commerce services and features. While we strive to implement reasonable security measures to protect your personal data in accordance with legal requirements, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION YOU PROVIDE ON THIRD-PARTY WEBSITES. These linked sites may have their own privacy policies and security practices. Even if such third parties are affiliated with us, we do not control these websites/apps/services, each of which has separate and independent privacy and data collection practices. You should read the terms and privacy policies published by those third parties on their respective websites.

5. How We Use Personal Information

We use your personal information to operate, provide, and improve Our Products, specifically:

5.1. Provide Products and Services:
We use your personal data to deliver Our Products and Services and process related transactions, including but not limited to registration, purchases, promotions, offers, and payments.

5.2. Measure, Support, and Improve Our Products:
We use your personal data to measure usage, analyze performance, fix issues, provide support, and improve and develop Our Products.

5.3. Recommendations and Personalization:
We use your personal data to recommend Products you may be interested in, identify your preferences, and personalize your experience with Our Products.

5.4. Communication:
We use your personal data to contact you regarding Our Products via various channels (e.g., email, chat, SMS, phone calls) and respond to your inquiries, requests, or complaints.

5.5. Marketing:
We use your personal information to market and promote Our Products in compliance with applicable laws. We may display targeted ads based on your interests.

5.6. Fraud Prevention and Credit Risk:
We use your personal data to detect and prevent fraud and abuse to protect the safety, security, and rights of our customers, ourselves, and others. We may also use scoring models to assess and manage credit risks.

5.7. Specific Purposes with Your Consent:
We may request your additional consent for specific uses of your personal data when we contact you.

6. Cookie Collection and Use

6.1. We, or authorized service providers and our advertising partners (as specified in Section 6.3 below), use cookies, pixels, and similar technologies (collectively referred to as “cookies”) to identify your browser or device, learn more about your preferences, provide you with essential features and services, and for additional purposes, including:

• Recognizing you when you sign in and/or use our services. This enables us to provide personalized recommendations, display tailored content, and deliver customized features and services.
• Remembering your accepted preferences, such as language and configurations, to enhance service quality and user experience.
• Conducting research and analysis to improve Our Products, helping us suggest new services and features that better meet your needs.
• Preventing fraudulent activity.
• Enhancing security.
• Delivering content, including advertisements, relevant to your interests on our websites and third-party websites.
• Measuring and analyzing the performance of Our Products.

6.2. Cookies enable you to take advantage of some of our essential features. If you block or reject our cookies, you may not be able to use certain products or services that require signing in, and you may need to manually adjust some preferences or language settings each time you revisit our websites.

6.3. Authorized third parties may also set cookies when you interact with Our Products. These typically include search engines, measurement and analytics providers, social media platforms, and advertising companies. These third parties use cookies in the process of delivering content, including interest-based advertisements, measuring ad effectiveness, and performing services on our behalf.

6.4. You can manage browser cookies through your browser settings. The “Help” feature on most browsers will tell you how to prevent the browser from accepting new cookies, how the browser notifies you when a new cookie is received, how to disable cookies, and when cookies expire. If you disable all cookies, we and third parties may not be able to transfer cookies to your browser. However, doing so may require you to manually adjust preferences and settings every time you visit our website, and some features or services may be limited or unavailable.

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7. How We Share Personal Information

7.1. Customer information is a vital part of our business. Nha Be Trading does not sell your personal data to any third party. However, in the course of business, we may need to use, process, disclose, and/or transfer your personal data to service providers, agents, affiliates, subsidiaries, and/or third parties located in or outside of Vietnam, for one or more of the above-mentioned Purposes, and such disclosures shall be conducted in compliance with applicable laws. These entities may process your personal data on our behalf for the specified purposes. We strive to ensure third-party service providers and Nha Be Trading affiliates keep your personal data secure from unauthorized access, collection, use, disclosure, or other similar risks. These third-party purposes include but are not limited to:

• Transactions involving third parties: We provide services, software, and content offered by third parties. You will be notified when third parties are involved in your transactions, and we will share relevant information accordingly.
• Third-party service providers: We engage other companies or individuals for programs such as promotional campaigns or cross-selling. Examples include: sending communications, processing payments, assessing credit and compliance risks, analyzing data, marketing and sales support (including advertising and event management), customer relationship management, and training. These providers are granted access to the necessary personal information only for the purpose of performing their functions and must comply with this Privacy Policy and relevant privacy protection laws.
• Restructuring or Business Transfers: In the course of business development, we may buy or sell businesses or reorganize operations in accordance with the law. In such cases, customer information, databases, and rights to use information may be among the assets transferred, but the acquiring party must comply with this Privacy Policy unless otherwise agreed by you. If Nha Be Trading or substantially all of its assets are acquired, your information may be transferred as part of the transaction.
• Protection of Us and Others: We may disclose account and other personal information when we believe it is appropriate to comply with the law, enforce our terms or other agreements, or protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with organizations to prevent fraud and reduce credit risk.
• At your discretion: You will be notified if your personal information may be shared with third parties not covered above, and you will have the opportunity to opt-out.

7.2. In cases where laws allow the collection, use, or disclosure of personal data without customer consent, such provisions will apply to Nha Be Trading by default.

7.3. If a user has access to others’ personal data via Our Products (“Data Recipient”), that user agrees to:
(i) Comply with all laws related to personal data protection in connection with any such data collection, processing, retention, or transfer;
(ii) Allow Nha Be Trading or the user whose personal data was collected (“Disclosing Party”) to request deletion of that data from the Data Recipient’s database; and
(iii) Allow Nha Be Trading or the Disclosing Party to review the collected content relating to them, in compliance with applicable law.

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8. Location of Personal Information

Nha Be Trading is headquartered in Vietnam. Depending on your interaction with Our Products, your personal data may be stored and accessed not only in Vietnam but also from various other countries. When transferring your personal data internationally, we ensure that such transfers comply with this Privacy Policy and applicable data protection laws.

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9. How We Protect Personal Information

At Nha Be Trading, data security is our top priority. Our systems are designed with features that aim to safeguard your data.

9.1. We employ technical and security measures to prevent unauthorized access or use of personal information. We also work with cybersecurity experts to stay up to date with the latest in network security. Personal data is stored securely on servers with firewalls, access controls, and encryption. We make every reasonable effort to ensure your personal data is protected within our systems.

9.2. We maintain personal data in accordance with relevant data protection laws. If you stop using Our Products or your access is terminated, we may still retain, use, and/or disclose your personal data as required by this Policy and applicable laws.

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10. Retention Period for Personal Information

We retain your personal data to ensure uninterrupted use of Our Products. The duration is determined by the purposes set out in this Policy, applicable legal obligations (e.g., tax and accounting), or as otherwise notified to you.

The retention period varies depending on the specific data type and use case. We will delete personal data after the legal retention period expires in accordance with applicable regulations.

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11. Communications, Notices, and Changes

11.1. As our business evolves, this Privacy Policy may be updated periodically. You should visit our website regularly for the latest version. Unless otherwise specified, the current version of this Privacy Policy applies to all data we have collected about you and your account. Any updates will not reduce the level of data protection provided for previously collected information without notifying affected customers and offering opt-out options.

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12. Additional Information for Europe

12.1. We provide additional information for individuals located in EU countries regarding their privacy rights, and our collection and use of personal data.

• Data Controller:
  Nha Be Trading Joint Stock Company (Head Office: 4 Ben Nghe, Tan Thuan Dong, District 7, Ho Chi Minh City, Vietnam) is the data controller for personal data collected or processed under this Privacy Policy.
• Legal Basis for Processing:
  We process your personal data based on one or more of the following legal grounds:
  • With your consent.
  • Where necessary to enter into or perform a contract with you or your organization;
  • To protect our legitimate interests, as permitted by law;
  • To comply with legal obligations;
  • In response to lawful requests; or

12.2. Transfers of Information Outside the European Union
When we transfer your personal information collected and stored within the European Union to a location outside the EU, such transfers will be conducted in accordance with the terms of this Privacy Policy and applicable data protection laws. This may include transfers pursuant to data transfer agreements incorporating the Standard Contractual Clauses approved by the European Commission.

[1] In accordance with Article 70 of Decree No. 52/2013/ND-CP
[2] In accordance with Article 71 of Decree No. 52/2013/ND-CP
[3] In accordance with Article 73 of Decree No. 52/2013/ND-CP
[4] In compliance with Article 68 of Decree No. 52/2013/ND-CP
[5] To meet the requirement of Article 16.2 of Decree No. 13/2023/ND-CP