Privacy policy | CashBerry

Privacy policy

1. INTRODUCTION

This Privacy Policy establishes the basic principles for handling Personal Data of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, Business code: 0316198194, address: Room GF-01, Ground Floor of MicroSpace Building, No. 14D1 Thao Dien Street, Thao Dien Ward, District 2, Ho Chi Minh City, Vietnam.

1.1. The corresponding policy is applied if the Customer uses, has used or intends to use the financial services provided by DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, including the relationship with the Customer established before This policy is in effect.

2. FOR THE PURPOSES OF THIS POLICY THE FOLLOWING DEFINITIONS ARE USED AS FOLLOWS:

2.1. Customer – any individual using, having used or expressing a desire to use or in any other way in connection with any service provided by DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY.

2.2. Personal Data – means any information relating to an identifiable or identifiable Customer.

2.3. Processing – all operations performed with Personal Data (including collection, recording, storage, alteration, grant of access, request fulfillment, transfer, etc.).

3. GENERAL TERMS

3.1. This policy is for the Company's Customers. This policy describes the general principles of how DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY handles Personal Data. Specific details about the handling of Personal Data may also be included in agreements signed between the Customer and DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY;

3.2. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY guarantees that, within the framework of applicable laws, the confidentiality of Personal Data has taken appropriate organizational and technical measures to protect Personal Data from unauthorized access, Handling or unlawful disclosure, loss, modification or destruction. Measures include:

3.2.1. Access control according to physical and logical;

3.2.2. Secure and encrypted communication channel;

3.2.3. The storage is encrypted for files and backups;

3.2.4. Store data in certified data centers;

3.2.5. Control access to the account (physical and logical);

3.2.6. Security training for employees.

3.3. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY may use authorized processors for the Processing of Personal Data. In such cases, DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY takes the necessary steps to ensure that those authorized processors handle Personal Data in accordance with the instructions of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY and comply with applicable laws and require adequate security measures.

3.4. The cookie policy DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY is available on the website of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY www.cashberry.vn.

4. LIST OF PERSONAL DATA

4.1. Personal Data may be collected from Customer, from Customer's use of financial services and from outside sources such as public and private registration or from other third parties.

4.2. The list of Personal Data that DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY mainly collects and processes is as follows:

4.2.1. Identity data at account opening, registration or other forms such as full name, date of birth, data related to identification documents (such as copy of passport, identity card), gender, phone labels, residential addresses, income information, personal descriptions and photographs and any other information you provide us to prove your eligibility to use our services, including including the information you provide to sign up for any services of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, to participate in any transaction on the website.

4.2.2. Contact data such as phone numbers, email addresses or apply to specific products of residence address (if any), language of communication;

4.2.3. Data about relationships with legal entities, such as data submitted by Customer or obtained from public registration or through a third party to make transactions on behalf of the mentioned entity, legal representative (operating on the basis of relevant authorization or on any other basis), contracting parties and contract participants, capital sources, beneficial owners (UBO), general manager of the company; shareholder; members of management or any other management unit; Data on habits, preferences and satisfaction such as the initiative of using services, the services used, personal settings, survey responses, lifestyle, hobbies, satisfaction of cutomer;

4.2.4. Data obtained and/or created during the performance of obligations arising from the law, such as data requested by investigating authorities, notaries, tax administration, courts and bailiffs, details of income, credit commitments, property ownership and outstanding balances;

4.2.5. Data on the origin of assets such as data relating to Customer's trading and business partners;

4.2.6. Data relating to services such as the execution of agreements or the failure of transactions that have been made, agreements entered into and expired, applications submitted, requests and complaints, benefits and service fees;

4.2.7. Data on participation in games and campaigns such as the number of points won in the game or the campaign;

4.2.8. Family data such as family information Customers, heirs and other related individuals;

4.2.9. Career data such as academic or professional occupation;

4.2.10. Financial data such as accounts, ownership, transactions, credits, income and debt obligations (if any);

4.2.11. The data allows DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY to take intensive measures on the prevention of money laundering and prevention of terrorist financing and to ensure compliance with international sanctions, including the purpose of business relationship;

4.2.12. Depending on the product of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, the customer has chosen data on the tax residence of the Customer such as data on the country of residence, tax code, nationality;

4.2.13. Communication data – collected when customers contact DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY via telephone, image and/or audio recording, e-mail, messages and other communication channels such as media social, data related to Customer's access at the website or contact via other DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY (such as chat).

4.2.14. Location data – processed on electronic communication networks or processed by electronic communication services, showing the location of electronic communication terminals, including the location of the terminals (address), location of the connection, GPS, Wi-Fi, ...

4.2.15. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY may collect and store information (including personal information) locally on Customer's device by using mechanisms such as browser web storage.

4.2.16. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY may use various technologies to collect and store information when customers visit the website DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, or similar technologies to identify Customer's browser or device.

5. PURPOSE AND BASIS OF THE HANDLING OF PERSONAL DATA

5.1. DIGITAL PLATFORM. When Customer registers to use the services and agrees to its data collection, DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY uses a variety of technologies to process Personal Data collected on Customer to ensure possibility. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY handles Personal Data for specific and necessary purposes only, based on certain legal grounds, including the legitimate interests of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY.

5.2. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY processes Personal Data primarily to:

5.2.1. Customer relationship management in general and provision, administration of access to financial services provided by DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY.

5.2.2. service provider and contract performance (agreement) signed. The handling is done on the basis of law and contract (transaction);

5.2.3. conduct credit and risk assessments;

5.2.4. notify customers of changes to services of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY;

5.2.5. administer the websites of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY for internal operations, including troubleshooting, data analysis, testing, research, statistics and surveys;

5.2.6. complete the websites of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY to ensure that the content is presented in the most effective way for you and your computer;

5.2.7. allow access to interactive features from the services of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, when the Customer chooses to do so;

5.2.8. measure or understand the effectiveness of advertising the services of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY to Customers and others, and to deliver Customer-related advertising;

5.2.9. to help DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY better understand the financial situation and behavior of customers, accordingly, DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY may make decisions about the management of customers' accounts;

5.2.10. protect the interests of the Customer and / or DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, check the quality of service provided by DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY and for the purpose of providing evidence of commercial transactions or other business communications (recorded conversations) based on the execution of the agreement, or to perform the steps required by the Customer prior to signing the agreement, or to comply with Customer's legal obligations or consent goods, or legitimate interests of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, to prevent, limit and investigate any misuse, illegal use, disruption of financial services or quality assurance, establish, implement, assign and protect legal complaints of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY;

5.2.11. provide additional services; Perform customer surveys, market analysis and statistics. Proposals to Customers the services of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY or carefully selected cooperation partners, including personalized recommendations, based on Customer's consent;

5.2.12. perform Customer surveys, analysis and market statistics; organize games and campaigns for Customers based on the legitimate interests of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, to improve the services of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, improve the customer service experience and develop the new products and services;

5.2.13. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY complies with legal obligations and identity verification. Comply with applicable laws, for example regarding the implementation of the principles of loan obligations, to prevent, detect, investigate, and report potential money laundering, terrorist financing, if the Customer goods subject to financial sanctions or individuals detected as having political influence;

5.2.14. prevent misuse of financial services and ensure the full provision of services. Allowing and controlling the access and operation of digital channels, preventing unauthorized access and misuse of such channels and to ensure information security based on: executing an agreement or taking steps at the request of the Customer before signing the agreement. To complete the technical systems, information technology infrastructure, customize service displays for equipment and develop services of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY such as testing and improving technical and mechanical systems. information technology infrastructure;

5.2.15. perform transactions on the system of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY and handle incoming and outgoing payments.

6. BASIS FOR ACCESSING AND USING PERSONAL DATA

6.1. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY access and use your Personal Data, if any of the following apply:

6.1.1. Customers intend to sign or have signed an agreement with DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY;

6.1.2. Customers have sent their consent;

6.1.3. processing Personal Data based on legal provisions;

6.1.4. for personal interestss, such as, for example:

6.1.4.1. to improve the quality of services of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, to ensure the consistency and sustainability of our operations, the comprehensiveness of our services is in line with our customers' expectations in order to achieve satisfaction. maximum of Customer;

6.1.4.2. to take an action or defend any legal claim and take other legal actions with the intent to avoid or minimize damage;

6.1.4.3. systematically monitor and prevent illegal activities based on conducting continuous assessment of the risks involved.

6.2. If Customer does not provide DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY Personal Data necessary for signing and / or executing agreements or terms as required by law or by agreement, then DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY has probably cannot provide the Customer with the service.

7. CREATE DOCUMENTATION, OFFER PERSONALIZED RECOMMENDATIONS, AND DELIVER AUTOMATED SOLUTIONS

7.1. Documentation refers to the automatic Processing of Personal Data used to evaluate certain Customer personal characteristics. Documentation used for direct marketing purposes. Automated Decision Making is used to manage risks and monitor transactions to combat fraud and based on the legitimate interests of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, compliance with legal obligations, performance of agreements or consensus. Customer will.

7.2. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY may process Personal Data to improve the user experience of digital services. Unless direct marketing is restricted by Customer, DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY may process Personal Data for the purpose of providing general and personalized offers for the services of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY.

7.3. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY always ensures that Customers can select and use a convenient tool to manage their privacy settings.

7.4. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY may also collect statistical data about Customers, such as typical behavioral and lifestyle types based on demographic data. Statistical data for segment profile creation can be collected from external sources and can be combined with internal data from DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY.

8. PROVIDER AND THE RECIPIENT OF PERSONAL DATA

8.1. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY uses the Personal Data that Customer provides to DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY when customers search for DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY and uses them, when Customer fills in the information form of the Customer, submit a request or request to send documents of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY at the website, application, by video surveillance equipment or telephone record, as stated above.

8.2. In addition, DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY may collect your Personal Data from other sources, such as:

8.2.1. other financial institutions;

8.2.2. banks, law enforcement organizations, and other organizations and registrants;

8.2.3. natural persons, when they provide data of spouses, children, blood relatives or marriages, guarantors, borrowers, mortgage providers, ...;

8.2.4. documents reserved for us and received from natural persons or legal entities when they perform contractual obligations towards us or obligations arising under the law (information from contracts, reports, ...);

8.2.5. legal entity, where you are the representative, employee, partner, shareholder, participant, owner, ... of the relevant legal entity;

8.2.6. partners or other legal entities who provide their services with our help;

8.2.7. The Borrower agrees to a customer rating evaluation through analysis from Information Technology, telecommunications and other information sources.

8.3. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY may collect personal information by monitoring technology tools and services, among other things, by email contact from or to DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY. Another example is when DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY gathers and generates information, when the Customer provides DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, for example, by identifying itself or by providing identification by means of electronic. In addition, DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY may obtain information from suppliers. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY can combine information obtained from a variety of sources.

8.4. Personal Data is shared with other recipients, such as:

8.4.1. Competent authorities (such as law enforcement, tax authorities, supervisory authorities) if DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY is obligated to share in order to comply with the legal obligations under applicable law, as well as Customer's sharing is necessary for this purpose, or the legitimate interests of third parties related to national security, law enforcement or litigation, legal proceedings, criminal investigations, protect the safety of any individual;

8.4.2. Other companies in the group, necessary for carrying out daily business activities and enabling maintenance and provision of Services, as well as for financial records, audits, risk assessments or we use common information systems or common hardware (servers) or are necessary to provide services;

8.4.3. Partners, banks and financial institutions, providers of various services to operate the technical infrastructure, we need to provide the Services;

8.4.4. Auditors, legal and financial advisors or any other handling department authorized by DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY;

8.4.5. Third parties maintain registers (such as credit bureaus, population registers, business registers or other registers that hold Personal Data);

8.4.6. Debt collectors when sending a request;

8.4.7. Courts, out-of-court dispute resolution agencies, and administrators are bankrupt or insolvent;

8.4.8. Others are involved in providing the services of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY, such as a postal or analytical service provider or any other service;

8.4.9. The Borrower agrees to authorize DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY to allow the third party, the Units with the data source to evaluate the above rating, to share ratings and other relevant information for the purpose. for the process of analyzing, evaluating, proposing and making decisions to grant me credit at DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY;

9. GEOGRAPHICAL AREA OF THE HANDLING

9.1. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY shares customers' Personal Data around the globe with companies in other groups to perform the activities specified in this Privacy Policy. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY may also subcontract the processing or sharing of your Personal Data with third parties in countries outside Vietnam.

10. STORAGE TERM

10.1. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY holds Personal Data for the purpose of accomplishing the goals set forth in this Privacy Policy unless longer retention periods are specified or permitted under applicable law. To determine the retention period of data, DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY uses criteria consistent with the provisions of law, such as checking complaints, protecting rights, solving problems, complying with time limits,...

10.2. The retention period may be based on agreement with the Customer, the legitimate interests of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY or applicable law (such as laws related to consumer loan statements, book preparation, anti-money laundering, civil law the, ...).

11. PRINCIPLES FOR PROTECTION OF PERSONAL DATA

11.1. The principles that DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY follow when collecting and using Personal Data entrusted to DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY and Personal Data obtained from other sources are as follows:

11.1.1. Personal Data is handled in a legal, fair and transparent manner (principles of legality, fairness and transparency);

11.1.2. Personal Data is collected for specific, clear, legal purposes and is not further processed in a manner incompatible with those purposes (goal restriction principle);

11.1.3. Personal Data is adequate, appropriate and only such data is required in relation to the purposes for which it is processed (data reduction principles);

11.1.4. Personal Data processed is accurate and, when necessary, updated (exact principles);

11.1.5. Personal Data is stored in a form that allows identification of the data subject does not exceed the time required for the purpose of data processing (storage limit principle);

11.1.6. Personal Data is processed in a manner that applies relevant technical or organizational measures to ensure adequate Privacy of Personal Data, including protection from unauthorized data processing or data processing. illegal and lost, destroyed or damaged data (security and integrity principles).

11.2. In the process of collecting and using Personal Data entrusted to DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY as well as data obtained from other sources, DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY commits as follows:

11.2.1. process Personal Data for clear and legal purposes;

11.2.2. do not process Personal Data for purposes other than those set out in the current Policy, unless otherwise provided by relevant laws;

11.2.3. process Personal Data legally, accurately, transparently and ensure the accuracy, identity and confidentiality of Personal Data processed;

11.2.4. ensure that unnecessary Personal Data is not processed;

11.2.5. process Personal Data no longer than is necessary for the purposes for which Personal Data is processed;

11.2.6. be responsible for compliance with the principles set forth in the current Policy and demonstrate such compliance;

11.2.7. perform other obligations arising under the law.

11.3. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY may display advertisements from third parties and other content associated with third party websites. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY cannot control or be responsible for our privacy practices and content from third parties. If Customer clicks on an ad or a third-party link, DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY will keep Customer aware that at the time Customer leaves the Service and any Personal Data will not be Privacy Policy this protects. Please read through the third-party privacy policy to learn how they collect and process your Personal Data.

12. CONTACT INFORMATION

12.1. Customers may contact DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY if they have any questions, withdraw consent, request to exercise the right to data subjects and complaints related to the use of Personal Data.

12.2. Contact details of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY are available on the page of DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY at www.cashberry.vn.

13. EFFECT AND AMENDMENT OF PRIVACY POLICY

13.1. DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY reserves the right to unilaterally amend the Privacy Policy at any time, in compliance with applicable laws, by notifying Customer of the amendments via the DIGITAL PLATFORM ONE MEMBER LIABILITY LIMITED COMPANY website without delay. more than a month before the amendment takes effect. Customer acknowledges and agrees that it is their responsibility to review this Privacy Policy periodically and be aware of any amendments.