Notification on the Processing of Personal Data according to Decree No. 13/2023/NĐ-CP issued by the Government on April 17, 2023

(updated on August 15, 2023)


A. Introduction

This Privacy and Data Protection Notice (“Notice”) is conducted by WIN . Research And Production Joint Stock Company  (“WIN R&D”) and describes the activities of WIN R&D related to the processing of personal data of WIN R&D customers.


1. Terminology in the Notification

– Current legal regulations refer to all laws, regulations, or binding provisions applicable to WIN R&D as stipulated by Vietnamese law.

– Personal data refers to information in the form of symbols, writing, numbers, images, sound, or similar forms in electronic environments that are associated with a specific individual or help identify a specific individual. Personal data includes basic personal data and sensitive personal data.

– Processing of personal data refers to one or more activities that affect personal data, such as collection, recording, analysis, verification, storage, modification, disclosure, combination, access, retrieval, retrieval, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, erasure of personal data, or other related actions.

– Third Parties refers to individuals or organizations that are not legal entities of WIN R&D but have contracts with WIN R&D to provide products or services, including but not limited to:

+ Independent individuals or companies.

+ Organizations directly or indirectly owned by WIN R&D.

+ The term “Third Parties” in this notification includes suppliers and other partner organizations.

– The terms Basic Personal Data, Sensitive Personal Data, Data related to electronic news pages or applications, and Marketing Data are understood according to the terms in Decree No. 13/2023.


2. Scope of this Notification

This notification regulates the manner in which WIN R&D collects and processes personal data of customers who use or interact with WIN R&D’s products, electronic news pages, or services, and/or individuals related to customers as required by law to collect; and/or who co-own or use WIN R&D’s products/services (referred to as “Customer”).

We encourage you to carefully read this notification and regularly check the electronic news pages for any changes that WIN R&D may implement according to the terms of this notification.

This notification is an integral part of the general terms and conditions and is an inseparable appendix to the service contract of each product or service that you have established with WIN R&D.


3. Acceptance of the Notification

By using any products, services, electronic news pages, applications, or devices, you are considered to have accepted this notification.

In the event that you do not accept the terms or withdraw your consent to the processing of your personal data for the purposes stated in this notification, withdrawing such consent may restrict, limit, suspend, terminate, obstruct, or prohibit the provision of products, services, features on electronic news pages, applications, or devices of WIN R&D, depending on the circumstances.

WIN R&D shall not be held responsible for any losses incurred by you, and the legal rights of WIN R&D shall be clearly reserved regarding such limitations, restrictions, suspensions, terminations, obstructions, or prohibitions.


4. Updating and Amending the Notification

WIN R&D reserves the right to modify, amend, adjust, supplement, or update this notification at any time.

Notifications of any modifications will be posted on our website and/or other communication channels that we deem appropriate. WIN R&D recommends that you regularly review this notification to stay updated on any changes and to be informed of how WIN R&D is protecting your personal data.

By continuing to use the electronic news pages, applications, or devices, you are deemed to continue using WIN R&D’s services and accepting this notification along with any related modifications or supplements.


B. Information Collected by WIN R&D


5. Types of Personal Data Collected by WIN R&D

The types of personal data collected by WIN R&D or its representatives, as outlined in this notification, may vary depending on applicable laws and regulations. The categories listed below include, but are not limited to, and may change depending on the product or service and your interaction with WIN R&D:

Basic personal data: Full name, phone number, email address provided voluntarily by you.

– Sensitive personal data: Not collected.

Data related to electronic news pages or applications: Technical data (including device type, operating system, browser type, browser settings, IP address, language settings, date and time of connection to the electronic news page, website usage statistics, date and time of connection to the website, location data, and other technical contact information); This information is collected anonymously, meaning that no specific individual can be identified from this data.

Marketing data: Interests in advertising; cookie data; clickstream data; web browsing history; responses to direct marketing; and opt-out choices for direct marketing, etc.


6. Methods of Collecting Personal Information

– Directly from customer

– From contact forms or chat boxes on the website.

– From exchanges or communications with you.

– From interactions or automated data collection technologies. WIN R&D may collect information including IP address, referring URL, operating system, electronic news page browser, and any other information automatically recorded from the connection.

– Cookies, flash cookies, pixel tags, electronic news beacons, or other tracking technologies.

– Third-Parties cookies, plugins, or social media connections.

– Any technology capable of tracking individual activities on devices or electronic news pages.

– Location information or other metadata provided by a device.

– Other means: WIN R&D may collect personal data when you interact with WIN R&D through any other means.

WIN R&D may receive personal data about you from other third parties.

For example: If you interact with third-Parties content or advertisements on the electronic news page or in the application, WIN R&D may receive your personal data from the relevant third Parties, in accordance with the third Parties’s legally compliant privacy policy.

Whenever personal data is collected in this manner, WIN R&D will ensure that relevant third parties have obtained your consent for: (i) providing WIN R&D with the personal data of the third Parties; and (ii) processing the data for WIN R&D’s purposes as stated in this notification. If you do not agree, please do not provide customer’s  personal data to third Parties.


C. How  WIN R&D use collected information?


7. Purposes of processing customer’s personal data

WIN R&D may process your personal data for the following purposes, including but not limited to:

– Providing products or services; implementing promotional programs, offers, and support from WIN R&D;

– Using and analyzing your information to develop, provide, continuously improve and enhance the quality of services, products, aiming to better meet your needs;

– Sending you information related to your transactions and needs, in compliance with the Current legal regulations on direct marketing;

– Online behavioral advertising or advertising based on needs and preferences;

– Displaying content of electronic news pages, applications, devices, and any customization you may choose;

– Managing content, promotional programs, surveys, or other features of electronic news pages, applications, devices, or survey platforms;

– Sending communications about managing your account and the features of electronic news pages, applications, or devices;

– Sending you information related to your transactions and needs, in compliance with the Current legal regulations on direct marketing;

– Verifying your identity and ensuring the security of your personal data;

Protecting against fraud, identity theft, and other illegal activities;

– To establish a legal basis, enforce legal rights, or protect the legal claims of WIN R&D;

– Complying with the Current legal regulations, relevant industry standards, and other current policies of WIN R&D;

– Notifying you of changes to products and services in cases where the management policies of the State, legal regulations, or the market undergo unusual changes or updates to WIN R&D’s Regulations/Policies;

– CCTV footage, in specific cases, may also be used for the following purposes: (i) for quality assurance purposes; (ii) for public security and occupational safety purposes; (iii) detecting and preventing suspicious, inappropriate, or unauthorized use of our utilities, products, services, and/or facilities; (iv) detecting and preventing criminal behavior; and/or (v) conducting investigations of incidents as required by government agencies;

– Other purposes as specified in the relevant Agreement when you participate/use WIN R&D’s services;

– Any other purposes specific to WIN R&D’s business operations; and

– In any other manner that we notify you at the time of collecting your personal data or before starting related processing or as required by other requests or permitted by applicable law.


D. WIN R&D’s protection of collected information


8. Protection of customer’s personal data

WIN R&D is committed to processing your personal data in a safe and secure manner, ensuring your rights regarding the processing of personal data in accordance with the current regulations of the applicable law.

WIN R&D employs appropriate data processing methods and implements technical and organizational security measures to prevent unauthorized access, reading, use, alteration, disclosure, unlawful destruction, or other processing of personal data.

However, it is important to note that the internet is not a completely secure environment, and WIN R&D cannot guarantee absolute security for the personal data you share over the internet. When transmitting personal data online, you should only use secure systems to access electronic news pages, applications, or devices. It is your responsibility to keep your access credentials for each electronic news page, application, or secure device confidential and secure. If you detect any misuse of your login information or unauthorized access, you should immediately notify WIN R&D and change your access password.


9. Disclosure of your personal data

WIN R&D will not sell, exchange, or rent (temporarily or indefinitely) your personal data without your consent in accordance with the current applicable law. WIN R&D may share or provide/use your personal data with the following parties:

– Employees and agents of WIN R&D who serve the purposes stated in this Notice.

– Third-Parties recipients outside of WIN R&D, including partners/subcontractors of partners, subsidiaries/affiliated companies of WIN R&D, and any trusted partners with a cooperating relationship with WIN R&D, who have agreed to comply with the obligations of customer data security and privacy in serving the purposes stated in this Notice.

– Partners with whom WIN R&D has an agreement to distribute WIN R&D products as the partner’s organizational agent for the purpose of providing insurance products according to customer needs.

– Third-Parties service providers to assist WIN R&D in operating business, operating electronic news pages, applications, or devices, providing you with selected products or services, or managing activities on behalf of WIN R&D, such as sending newsletters or conducting surveys, etc.

– In the case of proposed or completed sale, merger, or transfer of all or part of the business or assets of WIN R&D (including in the case of reorganization, dissolution, liquidation, or restructuring or change of control), WIN R&D may provide your personal data to the potential buyer or seller, or their representative, provided that WIN R&D has taken reasonable and lawful steps to ensure the security and confidentiality of your personal data.

– Relevant competent state agencies in accordance with the provisions of the law and/or when permitted by law.


E. Your rights and obligations as a Customer


10. Your rights and obligations regarding personal data collected by WIN R&D

WIN R&D can assist you in accessing and modifying your personal data held by WIN R&D.

When you want to access your personal data that we possess or if you believe that the personal data we hold is inaccurate, incomplete, misleading, or not up to date, if applicable, you may request us through our branch or through other channels that we may establish from time to time.

WIN R&D, with reasonable efforts, will comply with your requests for access or modification of your personal data when we receive a complete, valid, and relevant processing fee (if applicable) from you. Please note that WIN R&D may, at its discretion, allow modifications upon request and/or may request additional documentary evidence of new data to prevent fraud and inaccuracies.

WIN R&D commits to processing your data based on your consent for the purposes of this Notice, unless otherwise required by law. In the event that you perceive any violations regarding the processing of your personal data, you have the right to request our assistance in processing, to the extent permitted by us, to prevent or restrict the disclosure of your personal data, unless otherwise required by law.

Please note that other rights such as the right to complain, report, sue, claim compensation, or self-protection will be subject to legal provisions, unless otherwise agreed between you and WIN R&D.


F. Additional notes


11. Third-Parties services

You may encounter advertisements or other content on any electronic news page, application, or device that may be linked to websites or services of WIN R&D’s partners, advertisers, sponsors, or other third parties.

WIN R&D does not control the content or links appearing on third-Parties websites or services, and WIN R&D is not responsible for the activities used by the third-Parties websites or services linked to or from any electronic news page, application, or device.

These websites and services may comply with their own privacy policies and terms of use of third parties.


12. Direct marketing

As stated in this Notice and in compliance with the requirements of applicable laws, WIN R&D’s direct marketing partners or service providers may contact you via email, text messages, or other electronic means, at any time, to provide you with information related to products or services that you may be interested in.

If you wish to unsubscribe from receiving such notifications, WIN R&D attaches unsubscribe instructions in each notification.


13. Cookies

When you use or access WIN R&D’s electronic news pages, we may place one or more cookies on your device. A “cookie” is a small file placed on your device when you access an electronic news page. It records information about your device, your browser, and, in some cases, your preferences and browsing habits on electronic news pages.

WIN R&D may use this information to identify you when you revisit our electronic news pages, to provide personalized services on WIN R&D’s electronic news pages, to aggregate analytical data for a better understanding of electronic news page activities, and to improve our electronic news pages.

You can use your browser settings to delete or block cookies on your device. However, if you decide not to accept or block cookies from WIN R&D’s electronic news pages, you may not take full advantage of all the features of WIN R&D’s electronic news pages.

WIN R&D may process your personal data through cookie technology, in accordance with the provisions of this Notice. WIN R&D may also use remarketing measures to distribute advertisements to individuals who have previously accessed its electronic news pages.

Within the scope of third parties that have embedded content on WIN R&D’s electronic news pages (e.g., social media features), those third parties may collect your personal data (e.g., cookie data) if you choose to interact with their content or use the services of the third parties.


14. Data storage

WIN R&D will only store your personal data in connection with the purposes stated in this Privacy and Data Protection Notice. WIN R&D may also need to store your personal data for a period of time, such as when required by applicable law.


G. Contact us

For any inquiries related to the Privacy Notice, please contact us using the following information:

– Email address:
– Phone number: 0906 788 168
– HQ: L17-11, Floor 17, Vincom Center, 72 Le Thanh Ton, Ben Nghe Ward, District 1, Ho Chi Minh City, Vietnam
– WIN R&D CENTER: 36/8A Nguyen An Ninh Street, Di An City, Binh Duong Province, Vietnam