PRIVACY POLICY

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This Privacy Policy (“Policy”) is issued by SFVN INVESTMENT CORPORATION (“SFVN” or“We” or the “Company”), effective from the date it is officially published on https://sfvn-invest.com.vn/ (“Website”). It sets out general provisions on the protection of personal data of clients, including but not limited to individuals, partners, employees, collaborators, workers, and users of services provided by SFVN (“User” or “You”).

This Policy includes the following provisions, which may be updated, amended, supplemented, or replaced by SFVN from time to time, without requiring any consent from the User, and shall take effect immediately upon being updated and officially published on the Website and/or notified to the User through appropriate means.

By accessing and using SFVN’s Website, the User acknowledges that they have read, understood, and agreed to the conditions of this Policy.

1. Definitions and Interpretation

   In this Policy, unless otherwise provided, the following terms shall have the following meanings:

   • “Privacy Policy” or “Policy”: an inseparable part that shall be interpreted consistently with contracts, agreements, transactions, terms and conditions of use, and other documents/materials established between the User and SFVN.
   • “Personal Data”: information in the form of symbols, letters, numbers, images, sounds, or similar forms in an electronic environment associated with the User to identify or verify the User, including basic personal data and sensitive personal data, or other forms classified under Vietnamese law relating to personal data protection at each point in time.
   • “Processing of Personal Data”: one or more activities relating to Personal Data, including but not limited to collection, recording, analysis, verification, storage, modification, disclosure, combination, access, retrieval, recovery, encryption, decryption, duplication, sharing, transmission, provision, transfer, deletion, destruction of Personal Data, or other related actions as prescribed by law from time to time.
2. Purpose and Scope of Collection

   SFVN collects User’s Personal Data for the following purposes:

   • To manage and operate the Website.
   • To identify and verify User information (KYC/KYB).
   • To provide services to Users and conduct customer care.
   • To maintain and manage User accounts.
   • To comply with legal obligations under applicable laws.
   • To ensure system security and prevent violations.
   • To prevent money laundering, terrorism financing, fraudulent acts, and security risks.
   • For other purposes necessary for SFVN’s operations in providing Services to Users from time to time.

   SFVN collects Personal Data when Users:

   • Directly provide it to SFVN through agreements, contracts, transactions, forms, documents, or other related records
   • Interact with SFVN through the Website, such as via cookies, IP addresses, browser types, website access behavior... In addition, SFVN may use information related to the User’s access history with SFVN Vietnam to improve the Website’s responsiveness by offering relevant product/service recommendations that Users may be interested in.
   • From other lawful sources that SFVN may access, possess, or use.
3. Consent

   Any action by the User, including but not limited to registering, logging in, accessing, and using the Website, providing necessary information for using the Website and other linked websites owned/operated/managed by SFVN (if any), shall be understood as the User’s voluntary consent and authorization for SFVN to Process their Personal Data in accordance with this Policy and SFVN’s other applicable regulations (if any). If a User does not agree with this Policy, they may stop providing any information and/or exercise rights such as reviewing, updating, or modifying their personal information by logging into their account and editing details, or by requesting SFVN to do so. SFVN reserves the right to amend or supplement this Policy from time to time. SFVN encourages Users to frequently visit the Website to stay updated on the latest revisions, additions, or replacements of this Policy to ensure they are aware of and comply with the commitments here in.

4. Confidentiality Commitment

   SFVN is committed to the absolute confidentiality of User’s Personal Data and shall only Process Personal Data for the purposes committed to in this Policy and as required by applicable laws. The Processing of User’s Personal Data will only be carried out with the User’s consent, except in cases exempted under the law. SFVN commits to maintaining technical measures and performing updates to ensure the security of Personal DataProcessing, particularly to protect User’s Personal Data from risks during data transmission. SFVN does not provide User’s Personal Data to any third party, except in certain necessary cases. In such cases, SFVN ensures that the third party complies with personal data protection regulations at a level no less stringent than that applied by SFVN, including:

   • SFVN’s partners in the course of cooperation to provide Services to Users, limited only to necessary information.
   • Service providers engaged by SFVN for certain activities relating to the Website, where third parties may access or process Personal Data while delivering services to SFVN.
   • Joint programs or activities carried out with third parties, or outsourced for the purpose of providing Services to Users.
   • Upon request from competent State authorities, where SFVN has a legal obligation to provide User information.

   In the event the server storing Personal Data is attacked by hackers resulting in data loss, SFVN is responsible for notifying the competent State authorities for timely investigation and resolution, and informing Users accordingly.

5. Data Storage

   The User’s Personal Data shall be retained for as long as necessary or as required by law. Storage shall continue until a request for deletion is made, or the User logs into the issued account and performs deletion in accordance with the laws of Vietnam and/or the General Data Protection Regulation (EU) 2016/679 and other applicable international regulations. For Users who have entered into agreements, contracts, or transactions with SFVN, SFVN is required to retain their Personal Data in compliance with legal provisions on commerce and taxation. The User shall be solely responsible for maintaining the confidentiality and security of all activities carried out under their username, password, and email. The User is also responsible for notifying SFVN of any unauthorized use, abuse, or security breaches involving their username and password by third parties so that appropriate and timely measures may be taken.

6. Rights and Obligations of Users
   Users shall have the following rights:
   • The right to be informed of the Processing of their Personal Data.
   • The right to consent or not consent to the Processing of their Personal Data.
   • The right to access, review, edit, or request the correction of their Personal Data.
   • The right to delete or request deletion of their Personal Data.
   • The right to restrict data processing, with restrictions implemented within 72 hours of the request.
   • The right to request SFVN to provide their Personal Data.
   • The right to object to SFVN’s Processing of Personal Data in order to prevent or limit disclosure, or its use for advertising, marketing,...
   • The right to file complaints, denunciations, or initiate lawsuits as prescribed by law.
   • The right to claim compensation for damages in the event of violations of regulations on the protection of their Personal Data.
   • The right to self-protection through civil remedies in accordance with the law.

   Within the permitted scope, Users may exercise their rights by: (i) directly performing actions on the Website, or (ii)requesting SFVN to do so. If the User withdraws consent for SFVN to Process their Personal Data, such withdrawal may result in the limitation, restriction, suspension, cancellation, prevention, or prohibition of service provision, depending on SFVN’s policies at each point in time. SFVN shall not be liable for any resulting losses. For clarity, SFVN reserves its lawful rights, including but not limited to limiting, suspending, canceling, preventing, or prohibiting as stated above.

   The User undertakes to perform the following obligations:
   • To comply with the provisions of law, this Policy, and all regulations and guidelines of SFVN relating to the processing of the Personal Data of the Data Subject.
   • To ensure the completeness and accuracy of the Personal Data provided by the Data Subject to SFVN.
   • To promptly notify SFVN of any changes to the Personal Data already provided. SFVN shall safeguard the Personal Data of the Data Subject based on the information registered; therefore, SFVN shall bear no liability in the event that any incorrect information affects or limits the rights of the Data Subject. In the absence of such notification, should any risks or losses arise, the Data Subject shall bear responsibility for any errors, misuse, or fraudulent conduct in the use of the services resulting from their own fault or from their failure to provide timely, complete, accurate, and updated information, including financial damages and costs incurred due to inaccurate or inconsistent information provided.
   • To cooperate with SFVN, competent state authorities, or third parties in the event of issues arising that affect the Personal Data of the Data Subject.
   • To be solely responsible for any information, data, or consent created and provided in the online environment; and to assume liability in the event of any leakage or breach of Personal Data caused by their own fault.
   • To regularly update and comply with SFVN’s regulations and Personal Data Protection Policy as communicated to Customers from time to time or published on SFVN’s official website; and to act in accordance with SFVN’s instructions to clearly express full consent, partial consent, conditional consent, or refusal with respect to the purposes of Personal Data processing as notified by SFVN from time to time.
   • To respect and protect the Personal Data of others.
   • To perform any other obligations as prescribed by law.
7. Complaint and Dispute Resolution

   In the event of any complaint or dispute relating to this Policy, the User may contact SFVN for guidance and support at the following address

   SFVN INVESTMENT CORPORATION
   • Head Office Address: No. 9, D5 Street, Saigon Pearl Villas, 92 Nguyen Huu Canh, Thanh My Tay Ward, Ho Chi Minh City
   • Hotline: 0819 585 522
   • Email: info@sfvn-invest.com

   Any disputes or complaints arising between SFVN and the User shall be given priority for resolution through good faith negotiation and amicable settlement. Should the Parties fail to reach an agreement and/or the complaint remain unresolved, either Party shall have the right to submit the matter to the Vietnam International Arbitration Centre(VIAC) for resolution in accordance with the Rules of Arbitration of VIAC. The Parties agree that the seat of arbitration shall be Ho Chi Minh City.

8. Effectiveness and Amendments

   This Policy constitutes an integrated and inseparable agreement, having equal legal validity as the agreements, contracts, transactions, terms, and conditions of use previously entered into between SFVN and the User. By consenting to this Policy, the User acknowledges that they have read, fully understood, and unconditionally agreed to the entire contents hereof. In the event the User does not agree with this Policy, or only agrees with part of it, the User shall have the right to submit a written notice to SFVN specifying the parts not agreed upon. In such case, SFVN shall have the right, at its sole discretion, to continue providing the Services, to refuse to provide the Services, or to terminate the agreements/contracts/transactions entered into with the User, in accordance with SFVN’s policies and the applicable laws in force at each point in time