Article 1. TERMS DEFINITION

For the purposes of this Policy, unless the context otherwise requires, the following terms shall be understood and interpreted as follows:
1.1. TS24 means TS24 Joint Stock Company
 
1.2. Customer means
        • Individuals or legal representatives of individuals using and/or interested in TS24 Products and Services;
        • Individuals or legal representatives of individuals who have accessed and/or registered accounts at websites and/or applications owned by TS24.
 
1.3. TS24 Products and Services means
        • Products and services are directly researched, developed and provided to Customers by TS24;
        • Products and services are provided by TS24 in cooperation with third party(s) to Customers.

Article 2. PROCESSING OF PERSONAL DATA

2.1. TS24 processes Customer Personal Data in each specific case, including, but not limited to:
        • When the Customer or the Customer's legal representative contacts TS24 to request advice on TS24's Products and Services or expresses interest in TS24's Products and Services;
        • When Customers use TS24 Products and Services;
        • When Customers access and/or register for an account on websites and/or applications owned by TS24;
        • When the Customer agrees to provide Personal Data to TS24 through public sources, including but not limited to: meetings, events, seminars, conferences, social networks, or dialogue programs, discussions organized, sponsored or attended by TS24 and/or from cookies recorded on TS24's website;
        • When the Customer allows a third party other than TS24 to share the Customer's Personal Data with TS24;

        • When the Customer is a customer of an organization or enterprise to which TS24 contributes capital or purchases shares;
        • When requested by competent state agencies.
 
2.2. Customer Personal Data that TS24 processes (hereinafter referred to as “Personal Data”) includes but is not limited to and may vary depending on the product or service, Customer's interaction with TS24:
        2.2.1. Basic personal data
a) Surname, middle name and birth name, other names (if any);
b) Date of birth;
c) Sex;
d) Place of birth, place of birth registration, permanent residence, temporary residence, current residence, hometown, contact address;
đ) Nationality;
e) Personal image;
g) Phone number, ID number, personal identification number, passport number;
h) Customer credit score: expressed in the form of a score, is the result of TS24 processing and analyzing data of Customers using the service, in order to evaluate, analyze, and predict activities such as: habits, preferences, reliability, behavior, location, trends, capacity and other cases, supporting the provision of TS24 products to Customers in the best way.
        2.2.2. Sensitive personal data
a) Data on crimes and criminal acts collected and stored by law enforcement agencies;
b) Customer information of credit institutions, foreign bank branches, payment intermediary service providers, and other licensed organizations, including: customer identification information as prescribed by law, account information, deposit information, deposited assets information, transaction information, information about organizations and individuals who are guarantors at credit institutions, bank branches, and payment intermediary service providers;
c) Data about an individual's location is determined through location services.
        2.2.3. Other personal data that does not fall into the category of basic personal data and sensitive personal data specified in Article 2.2.1 and Article 2.2.2.
 
2.3. TS24 will notify the Customer of the Personal Data required to be provided and/or optional to be provided at the time of collecting the Customer's Personal Data. If the required Personal Data is not provided upon request, the Customer will not be able to use certain TS24 Products and Services and/or TS24 may refuse to provide TS24 Products and Services to the Customer without incurring any compensation and/or penalties.
  
2.4. At any time, the Customer may voluntarily provide TS24 with Personal Data that is not required by TS24. When the Customer provides Personal Data to TS24 for any reason, it means that the Customer has agreed to allow TS24 to process such Personal Data for the Purpose stated in this Policy or for the purpose stated at the time the Customer provides such Personal Data. In addition, when proactively providing information that is not required by TS24, the Customer is requested not to provide sensitive Personal Data as prescribed by law at that time. TS24 will not process and will not bear any legal responsibility for sensitive Personal Data voluntarily provided by the Customer that is not required by TS24.

Article 3. PURPOSE OF PERSONAL DATA PROCESSING

TS24 may process Customer Personal Data for one or more of the purposes listed below (“Purpose”) including, but not limited to, the following Purposes:

3.1. Verify the accuracy and completeness of the information provided by the Customer; identify or authenticate the Customer's identity and perform the Customer authentication process; Process the registration to use TS24's Products and Services;

3.2. Assessing the Customer's profile and eligibility for using TS24's Products and Services. TS24 may use scoring methods and check the Customer's history of using TS24's Products and Services to assess and ensure the ability to pay for payment obligations and other related obligations during the process of providing TS24's Products and Services to the Customer;

3.3. Manage and evaluate business activities including designing, improving and enhancing the quality of TS24 Products and Services or carrying out marketing communication activities; Conduct market research, surveys and analyze data related to TS24 Products and Services;

3.4. Contacting Customers to exchange information, resolve requests, complaints, deliver invoices, statements, reports or other documents related to TS24 Products and Services through various channels (e.g. email, chat) and to respond to Customer requests. This includes contacting Customers (or other necessary parties) to notify Customers of information related to the use of TS24 Products and Services;

3.5. Advertising, marketing based on Customer's interests and service usage habits: TS24 may use Personal Data to advertise and market to Customers about TS24's Products and Services, promotions, research, surveys, news, updates, events, contests with prizes, awarding related prizes, advertisements and related content about TS24's Products and Services or those of TS24's partners. In case the Customer does not want to receive emails, messages and/or periodic newsletters for advertising and marketing purposes from TS24 at a frequency depending on TS24's policies from time to time and in accordance with legal regulations, the Customer may click on the "Unsubscribe" link in the advertisement content or contact TS24 according to the contact information specified in this Policy for support;

3.6. Prepare financial reports, performance reports or other relevant reports as prescribed by law;

3.7. Comply with legal obligations as prescribed by law;

3.8. Prevent fraud or reduce threats to the life, health of others and public interests: TS24 may use Customer's personal information to prevent and detect fraud and abuse to protect Customers, TS24 and related entities;

3.9. Internal management;

3.10. Other purposes related to the purposes stated above.

Article 4. HOW PERSONAL DATA IS PROCESSED

TS24 applies one or more activities affecting Personal Data such as: collecting, recording, analyzing, validating, storing, editing, publicizing, combining, accessing, retrieving, withdrawing, encrypting, decrypting, copying, sharing, transmitting, providing, transferring, deleting, destroying personal data or other related actions.

Article 5. START TIME AND END TIME OF DATA PROCESSING

5.1. Data processing start time

From the time the Customer accepts this Policy.

5.2. Data processing end time

Unless otherwise provided by Vietnamese law or the Customer requests to terminate the processing of the Customer's Personal Data, TS24 shall terminate the processing of Personal Data upon completion of the Purpose specified in this Policy.

Article 6. SHARING OF PERSONAL DATA

6.1. To carry out the Purposes set out in this Policy, TS24 may share Customer Personal Data with:
        6.1.1. TS24's affiliated agents: Some of TS24's Products and Services provide, therefore, sharing Personal Data with these entities is necessary and only for the purpose of providing services to Customers;
        6.1.2. Third Party Service Providers: TS24 uses and/or cooperates with other companies and individuals to perform certain tasks and programs such as promotional programs for Customers, market research, product analysis and development, and strategic consulting. These Third Party Service Providers have the right to access, collect, use, and process Personal Data necessary to perform their functions, including but not limited to advertising, introducing, and providing other products/services within the TS24 ecosystem or of partners cooperating with TS24 or cooperating with agents. These Third Party Service Providers must comply with the laws on Personal Data protection as Data Processors;
        6.1.3. Business restructuring: In the course of business development, TS24 may sell or buy businesses or restructure businesses in accordance with legal regulations and business production needs. In such transactions, Personal Data is one of the transferred business assets but the transferee must still comply with the provisions of this Policy;
        6.1.4. Protection of the legitimate rights and interests of TS24 and other entities: TS24 may disclose Personal Data where TS24 has reasonable grounds to believe that such disclosure is required by law, by a regulatory authority, to enforce or apply the terms and other agreements of TS24 or to protect the rights, property or security of TS24, TS24's customers, or any other entity. The above may include exchanging information with other companies and organizations for the purpose of preventing and detecting fraud and reducing asset and credit risks, or disclosing certain types of information where TS24 receives a legally binding request from a competent governmental authority;
        6.1.5. Depending on the Customer's choice: In addition to the cases mentioned above, Personal Data may be shared with third parties for the purposes specified in Article 3.5 of this Policy and the Customer will have the right to not consent to the sharing of information as specified in Article 8.4 of this Policy.

6.2. TS24 does not share Personal Data for profit purposes.

Article 7. STORAGE OF PERSONAL DATA

7.1. Customer Personal Data stored by TS24 will be kept confidential. TS24 will, within its capacity, endeavor to take reasonable measures to protect Customer Personal Data.

7.2. Location of Personal Data Storage
To the extent permitted by law, TS24 may store Customer Personal Data in Vietnam. TS24 applies data security standards in accordance with current legal regulations.

7.3. Personal Data Retention Period
TS24 only stores Customer Personal Data for the period necessary and reasonable to fulfill the Purposes. In case the current law stipulates the period of storage of Personal Data even after the Purposes stated in this Policy have been fulfilled, TS24 is obliged to comply with the provisions of the law.

Article 8. CONTROL OF PERSONAL DATA

8.1. Right to Know and Right to Consent
By this Policy, TS24 informs Customers about the processing of their Personal Data before processing Personal Data. At the same time, Customers have the right to agree or disagree with the terms and conditions of this Policy by checking or not checking the box "I have read and agree to the Terms of Service and Privacy Policy of TS24".

8.2. Right to access and request provision of Personal Data
Customers have the right to access TS24 applications/websites and/or contact TS24 directly to check and extract Personal Data that Customers have provided to TS24 for the Purposes specified in this Policy. In case Customers cannot access, extract or have difficulty accessing, extracting Personal Data, Customers can contact TS24 for support.

8.3. Editing rights
Customers have the right to edit their Personal Data provided that such editing does not violate the provisions of law. In case the Customer cannot edit or has difficulty editing Personal Data, the Customer can contact TS24 for support.

8.4. Right to object, restrict, withdraw consent to data processing
In case the Customer does not want to receive marketing, advertising and promotional content from TS24 and wants to withdraw the previous consent (if any) and/or object to the continued use of his/her personal information for the above purpose, the Customer can click on the "Unsubscribe" link in the advertising content or contact TS24 according to the contact information specified in this Policy for support. If the Customer does not want to receive notifications from TS24's application, please adjust the notification settings in the application or your device.

8.5. Right to Erasure of Personal Data
The Customer has the right to request TS24 to delete the Customer's Personal Data provided that the Customer's request is in accordance with the provisions of law on the provision of products. However, requesting the deletion of Personal Data may result in TS24 being unable to provide some TS24 Products and Services to the Customer, which means that TS24 may unilaterally terminate the contract without having to compensate the Customer due to changes in the conditions for performing the contract. Therefore, TS24 recommends that the Customer consider carefully before requesting TS24 to delete Personal Data.

8.6. Right to complain
Customers have the right to complain directly to TS24 or to competent state agencies in case the Customer believes that TS24 violates the provisions of law related to the protection of Personal Data.

Article 9. PROTECTION OF PERSONAL DATA

9.1. TS24's obligations
TS24 strives to ensure that Customer Personal Data is protected from violations of Personal Data protection regulations. TS24 maintains this commitment to the security of Personal Data by implementing physical, electronic and managerial measures to protect Personal Data, including:
        • TS24's official website servers are protected by a "firewall" and TS24's system is always checked to prevent violations of Personal Data protection regulations.;
        • TS24 will take all reasonable steps to ensure that Customer Personal Data, Personal Data provided by the Personal Data Controller Partner is not retained for longer than necessary and that TS24 will always comply with the legal requirements relating to the retention of Personal Data.

9.2. Customer Obligations
Customers are responsible for protecting their Personal Data as follows:
        • Actively take measures to prevent unauthorized access to passwords, manage and use your account, mobile devices (including but not limited to smartphones, computers, tablets, laptops) by logging out of your account after use, setting a strong and difficult-to-guess password and keeping your login information and password confidential. TS24 is not responsible to the Customer in case the Customer's password is disclosed/lost, stolen or compromised, or any activity on the Customer's account using an unauthorized password or losing/misplacing a mobile device leading to unauthorized persons using the service or the system being illegally compromised by a third party even though TS24 has taken full measures to protect the system;
        • Customers are responsible for updating documents amending this Policy (if any) on TS24's official information channels;
        • Upon acceptance of all terms and conditions of this Policy, the Customer is responsible for providing accurate and complete Personal Data as required by TS24 and for fulfilling the responsibility of notifying TS24 immediately upon discovering any violation of the regulations on Personal Data protection. The Customer may proactively provide Personal Data beyond the requirements of TS24 provided that the Customer must comply with the provisions of Article 2.4 of this Policy;
        • Customers are responsible for respecting the Personal Data of other subjects and complying with the provisions of law on Personal Data protection, participating in preventing and combating violations of regulations on Personal Data protection.

Article 10. POSSIBLE UNWANTED CONSEQUENCES AND DAMAGES

10.1. TS24 uses various information security technologies to protect Customer Personal Data from unwanted access, use or sharing. However, no data can be 100% secure. Therefore, TS24 is committed to maximally securing Customer Personal Data. Some undesirable consequences and damages that may occur include but are not limited to:
        • Hardware or software errors during the processing of Personal Data that cause loss of Customer Personal Data;
        • The security hole is beyond TS24's control, the system was hacked, causing the leak of Customer Personal Data;
        • Customers expose their Personal Data due to: carelessness or fraud; accessing websites/downloading applications containing malware.

10.2. TS24 recommends that Customers strictly implement their responsibilities to protect Personal Data as prescribed in Article 9.2 of this Policy and as prescribed by law.

10.3. In case the data storage server is hacked, leading to the loss of Customer Personal Data, TS24 will be responsible for reporting the incident to the authorities for timely investigation and notification to the Customer.

Article 11. USE OF COOKIES

11.1. Cookies may be used on the TS24 website. “Cookies” are small text files stored on the Customer’s computer hard drive to help customize the user’s website experience. TS24 has a policy of using cookies to make navigating the website easier and to facilitate the login process. Website statistics are processed by third parties, and therefore, the Customer’s IP address will be transmitted to third parties for statistical reporting purposes only.

11.2. When TS24 collects information through the TS24 website, TS24 automatically collects non-personal information related to the use of the website but does not identify the user, including but not limited to: the IP address of the personal computer, the IP address of the Internet service provider, the date and time of accessing the website, the operating system, the items accessed on the website, the content downloaded from the website and the website address that directly led you to the TS24 website. TS24 may use this non-personal information to serve statistical reports on website traffic and website usage behavior. This analysis information is not capable of identifying the Customer.

11.3. If the Customer does not wish to use cookies, most web browsers allow users to refuse cookies by changing the privacy settings on the browser. Refusing cookies will not affect the navigation of the website. However, some functions of the website may be affected. After completing the access to the website, the Customer can still delete cookies from the system if desired.

Article 12. ADVERTISING ON THE INTERNET AND THIRD PARTIES

TS24's applications/websites may include third-party advertisements and links to other websites and applications. Third-party advertising partners may collect information about Customers when Customers interact with their content, advertisements or services. Any access to and use of third-party links or websites is not governed by this Policy, but is instead governed by the privacy policies of those third parties. TS24 is not responsible for the information practices of third parties.

Article 13. PROCESSING OF PERSONAL DATA WITHOUT THE CONSENT OF THE DATA SUBJECT

TS24 may process Personal Data without the consent of the Data Subject in the following cases:

13.1. In case of emergency, it is necessary to immediately process the relevant Personal Data to protect the life or health of the data subject or another person;

13.2. Disclosure of personal data as required by law;

13.3. Data processing by competent state agencies in case of emergency regarding national defense, national security, social order and safety, major disasters, dangerous epidemics; when there is a threat to national security and defense but not to the extent of declaring a state of emergency; preventing and combating riots, terrorism, preventing and combating crimes and violations of the law according to the provisions of law;

13.4. To perform the data subject's contractual obligations with relevant agencies, organizations and individuals as prescribed by law;

13.5. Serving the activities of state agencies as prescribed by specialized laws.

Điều 14. SỬ DỤNG API GOOGLE WORKSPACE VÀ CHÍNH SÁCH PHÁT TRIỂN MÔ HÌNH AI/ML

Tuân thủ quy định sử dụng Google Workspace API: Chúng tôi khẳng định rằng Google Workspace API được truy cập thông qua dịch vụ của chúng tôi không được sử dụng để phát triển, cải thiện hoặc đào tạo các mô hình trí tuệ nhân tạo (AI) hoặc máy học (ML) tổng quát.

Mục đích sử dụng API: Việc chúng tôi sử dụng API Google Workspace chỉ giới hạn ở việc nâng cao trải nghiệm người dùng và chức năng của các dịch vụ như được mô tả rõ ràng trong tài liệu dịch vụ của chúng tôi và không mở rộng sang bất kỳ hình thức phát triển mô hình AI hoặc ML nào.

Xử lý và xử lý dữ liệu: Mọi dữ liệu được truy cập thông qua API Google Workspace đều được xử lý theo chính sách bảo mật của chúng tôi, tuân thủ nghiêm ngặt mục đích đã nêu và không nhằm mục đích phát triển các công nghệ AI hoặc ML tổng quát.

Hạn chế về việc sử dụng dữ liệu: Chúng tôi đảm bảo rằng không có dữ liệu nào thu được từ API Google Workspace sẽ được sử dụng để đào tạo, hiệu chỉnh hoặc cải thiện khả năng của các hệ thống, thuật toán hoặc mô hình AI hoặc ML.

Tính minh bạch và công khai: Chúng tôi cam kết duy trì tính minh bạch hoàn toàn về việc sử dụng dữ liệu thu được từ API Google Workspace và sẽ liên tục cung cấp thông tin công khai rõ ràng về các mục đích cụ thể mà dữ liệu này được sử dụng.

Các biện pháp bảo mật và quyền riêng tư: Các biện pháp bảo mật và quyền riêng tư mạnh mẽ được triển khai để bảo vệ dữ liệu được truy cập thông qua API Google Workspace, đảm bảo dữ liệu được xử lý tuân thủ mọi luật và quy định hiện hành, bao gồm GDPR, CCPA và các luật và quy định khác.

Chia sẻ và truy cập dữ liệu của bên thứ ba: Không có việc chia sẻ dữ liệu thu được thông qua API Google Workspace với bất kỳ bên thứ ba nào cho mục đích phát triển mô hình AI hoặc ML. Bất kỳ hoạt động chia sẻ dữ liệu nào đều được nêu rõ trong chính sách bảo mật của chúng tôi.

Article 14. CONTACT INFORMATION

In case the Customer has any questions about this Policy or wants to exercise the Customer's rights related to Personal Data, please contact TS24 by the methods and information below:
        • Contact the switchboard according to the information on TS24's official websites/applications at each time.
        • Send the document to TS24's head office at 33 Ly Chinh Thang, Vo Thi Sau Ward, District 3, Ho Chi Minh City, Vietnam.
        • Contact directly at TS24 agents nationwide.
        • Other contact methods such as Livechat, contact via TS24's official fanpage, customer care email are provided to customers at all times.

Article 15. ADJUSTMENTS AND AMENDMENTS

TS24 may adjust this Policy at any time and publicly post the adjusted Policy on TS24's official information channels. The Customer's continued use of TS24's Products and Services and not having any complaints about the adjusted Policy is understood as the Customer's acceptance of the adjusted Policy of TS24.