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Internal Rule of Entrance

Privacy Policy

1. User’s consent

   o  Club V respects privacy and strives to protect the User’s personal data tocomply with the provisions of Vietnamese laws. The Privacy Policy governs andregulates Club V’s collection and processing practices of personal data of theUsers during the Users’ access or interaction with the Website. Club V takesthe privacy of information of Users seriously. This Privacy Policy applies toall data collected by Club V or provided by Users in relation to using theWebsite.

   o  The Privacy Policy is set out in accordance with Decree No. 13/2023/ND-CPprescribing personal data protection and relevant laws (the “Decree No. 13”).The Users are required and responsible for reading these contents carefully andregularly checking back for updates on any changes set out in the PrivacyPolicy. By accessing the Website or by agreeing to allow Club V to collect andprocess the personal data of the Users in a manner of compliance with the laws,the Users accept the policies and regulations described in this Privacy Policywithout any limitation or reservation. If Users refuse or disagree with anyprovisions of the Privacy Policy, please stop accessing the Website.

   o  For clarification, Club V reserves the right to suspend or terminate theaccess of Users at the time the Users refuse to accept these terms without anynotice. The use of the Website will be provided to the Users once Club Vobtains the Users’ consent to the collection and processing of personal data inaccordance with this Privacy Policy.

2. Definitions

  2.1  “Personal data” means information in the form of symbols, scripts, digits,images, sounds, or similar forms in the electronic environment that isassociated with a specific person or helps identify a specific person. Personaldata includes basic personal data and sensitive personal data.

 2.2  “Basicpersonal data” include:

   o  Full name, middle, and birth name, and other names (if any);

   o  Date, month, year of birth; date, month, year of death or disappearance;

   o  Gender;

   o  Place of birth, place of birth registration, permanent residence, temporaryresidence, current residence, hometown, contact address;

   o  Nationality;

   o  Images of individuals;

   o  Phone number, identity card number, personal identification number,passport number, driver’s license number, license plate number, personal tax,identification number, social insurance number, health insurance card number;

   o  Marital status;

   o  Information about family relationships (parents, children);

   o  Information about the individual’s digital account; personal datareflecting activities and history of activities in cyberspace;

   o  Other information that relates to a specific person or helps identify aspecific person that does not fall under the category of sensitive personaldata.

 2.3. “Sensitive personal data” means personal data associated with individualprivacy that, when infringed, will directly affect the legitimate rights andinterests of individuals, including:

   o  Political views, religious views;

   o  Health and personal status are recorded in the medical record, excludinginformation about blood type;

   o  Information related to racial and ethnic origin;

   o  Information about inherited or acquired genetic characteristics ofindividuals;

   o  Information about individual physical properties, biologicalcharacteristics;

   o  Information about the sex life, sexual orientation of the individuals;

   o  Data on crimes and offenses collected and stored by law enforcementauthorities;

   o  Information on customers of credit institutions, foreign bank branches,payment service providers and other licensed institutions, including:customer identification as prescribed by laws, accounts, deposits, depositedassets, transactions, organizations and individuals that are guarantors atcredit institutions, bank branches, and payment service providers;

   o  Data about the individual’s location determined through location services;

   o  Other personal data provided by laws is specific and requires necessarysecurity measures.

 2.4  “Processing of personal data” is one or more activities affecting personaldata, such as collection, recording, analysis, confirmation, storage,modification, publicity, combination, access, retrieval, encryption,decryption, copying, sharing, transmission, provision, transfer, deletion,destruction of personal data or other related actions.

3. Collection of personal data

   o  Club V may collect directly or indirectly personal data of the Users in thecourse of accessing and using the Website of Users.

4. Notification for processing personal data

 4.1  Notification is given once prior to the processing of personal data by Club V.

 4.2  Contentsof notification to Users regarding the processing of personal data include:

   o  Purpose of processing;

   o  Type of personal data used related to the purposes of processing specifiedin section 4.2(a) of this Privacy Policy;

   o  Method of processing;

   o  Information about other organizations and individuals related to thepurposes of processing specified in section 4.2(a) of this Privacy Policy;

   o  Possible unexpected consequences and damages;

   o  Start time and end time of data processing.

 4.3  Notification to Users will be presented by Club V in a format that can beprinted, and copied in writing, including in electronic or verifiable format

 4.4  Club Vdoes not need to provide a personal data processing notification to Users inthe following cases:

   o  Users are aware of and fully consent to the contents of sections 4.1 and4.2 of this Privacy Policy before consenting to the collection of personal databy Club V, in accordance with the provisions of section 11 of this PrivacyPolicy;

   o  Personal data processed by competent state authorities for the purpose ofserving the operation of state authorities in accordance with laws.

5. Processing of personal data without the consent of the Users

 5.1. In case of emergency, relevant personal data needs to be immediately processed toprotect the life and health of Users or others. Club V is responsible forproving this case.

 5.2. The disclosure of personal data in accordance with the laws.

 5.3. The processing of personal data by competent state authorities in case of anemergency of national defense and security emergency, social order and safety,major disasters, or dangerous epidemics; when there is a threat to nationalsecurity or defense but not to the extent of declaring a state of emergency;preventing and combating riots, terrorism, preventing and combating crimes andviolations of laws in accordance with the provisions of laws.

 5.4. Performing the obligations under the User’s contract with relevant agencies,organizations, and individuals in accordance with the provisions of laws.

 5.5. Serving the operation of state authorities prescribed by specialized laws

6. Use of personal data

 6.1  Any ofthe above data may be required by the Website from time to time in order toprovide Users with the best possible experience when using the Website.Specifically, the data may be used by Club V for the following reasons inaccordance with this Privacy Policy:

   o  Improvement of our services;

   o  Other purposes for which the data was provided to Club V by the Users.

 6.2  Club Vuses the personal data collected from the Users to provide Users’ support,undertake necessary security and identify verification checks, meet certainbusiness requirements, and for any other purpose related to the operation ofthe Website. User’s personal data may also be used by Club V to provide Userswith:

   o  Promotional offers and information regarding our services; and

   o  Promotional offers and information regarding the services of our partners,in order to enlarge the range of provided services and improve our customerservice.

7. Provision of personal data

 7.1   Users areentitled to ask Club V to provide themselves with their personal data.

 7.2  Club Vshall have the right:

   o  To provide personal data of Users to other organizations and individualswith the consent of Users, unless otherwise provided for by laws;

   o  To provide personal data of Users to other organizations or individuals onbehalf of Users when Users agree to allow representation and authorizationunless otherwise provided for by laws.

 7.3  Theprovision of personal data of Users is provided by Club V within 72 hours afterthe User’s request unless otherwise provided by laws.

 7.4  Club Vdoes not provide personal data under the circumstances:

   o  Causing harm to national defense, security, social order, and safety;

   o  The provision of personal data of Users may affect the safety, physical ormental health of others;

   o  Users do not agree to provide, allow to represent, or authorize to receivethe personal data.

 7.5  Formof request for personal data:

   o  Users directly or authorize others to come to Club V’s head office torequest personal data. Club V’s staff receiving requests is responsible forinstructing Users or Users’ authorized representatives to fill in the PersonalData Request Form. In case the Users or Users’ authorized representativerequesting the information is illiterate or has a disability that cannot writethe request, Club V’s staff receiving the request is responsible for helping tofill in the contents of the Personal Data Request Form.

   o  To send the request form for personal data in accordance with the formsprescribed by laws via electronic network, postal service, fax to Club V.

 7.6  Therequest form for the provision of personal data shall be in Vietnamese,including the following main contents:

   o  Full name, first name; place of residence, address; identity card number,citizen identification card or passport number; fax number, telephone number,email address (if any);

   o  Personal data requested to be provided, specifying the name of thedocument, dossier;

   o  Forms of provision of personal data;

   o  Reasons and purposes of request for provision of personal data.

 7.7  In caseof a request to provide personal data specified in section 7.2 of this PrivacyPolicy, it must be accompanied by the written consent of the individual ororganization concerned.

 7.8  Receivingrequests for personal data:

   o  Club V is responsible for receiving requests for personal data andmonitoring the process and list of personal data provisions upon request;

   o  Where the requested personal data is not within our competence, Club V mustnotify and instruct the requesting organization or individual to the competentauthority or clearly notify the inability to provide personal data.

 7.9  Handlingrequests for personal data Upon receipt of a valid request for personal data,Club V shall inform the duration, place, and form of provision of personaldata; actual costs for printing, copying, capturing, and sending informationvia postal and fax services (if any) and payment methods and terms; providepersonal data in accordance with the orders and procedures specified in thesection 7 of this Privacy Policy.

8. Correction of personal data

   o  Club V corrects the User’s personal data after obtaining the User’s consentas soon as possible or in accordance with specialized laws. In case this is notpossible, Club V shall notify Users after 72 hours after receiving the requestto correct the Users’ personal data.

   o  Users have access to view and correct their personal data after it has beencollected by Club V in accordance with your consent unless otherwise providedby laws. Where direct correction is not possible due to technical or otherreasons, Users are entitled to request Club V to correct their personal data.

   o  Users have access to view and correct their personal data after it has beencollected by Club V in accordance with your consent unless otherwise providedby laws. Where direct correction is not possible due to technical or otherreasons, Users are entitled to request Club V to correct their personal data.

9. Retention, deletion, destruction of personal data

 9.1. Users areentitled to request Club V to delete your personal data in the following cases:

   o  Realizing that it is no longer necessary for the purpose agreed andaccepting the possible damages that may occur when requesting deletion of data;

   o  Withdrawal of consent;

   o  Object to the processing and Club V has no legitimate reason to continuethe processing;

   o  Personal data is processed in contravention of the agreed purpose, or theprocessing of personal data is in violation of the provisions of laws;

   o  Personal data must be deleted in accordance with the provisions of laws.

 9.2  Deletionof personal data will not apply at the request of Users in the following cases:

   o  Data deletion is not allowed by laws;

   o  Personal data are processed by competent state authorities for the purposeof serving their operations in accordance with laws;

   o  Personal data that has been public in accordance with the provisions oflaws;

   o  Personal data are processed to serve legal requirements, scientificresearch and statistics in accordance with the provisions of laws;

   o  In case of an emergency of national defense and security, social order andsafety, major disasters or dangerous epidemics; when there is a threat tonational security or defense but not to the extent of declaring a state ofemergency; preventing and combating riots, terrorism, preventing and combatingcrime and violations of laws;

   o  Respond to an emergency that threatens the life, health or safety of Usersor other individuals.

 9.3  Datadeletion is done within 72 hours after the User’s request for all personal datacollected by Club V, unless otherwise required by laws.

 9.4  Club Vstores personal data in a form consistent with our operations and takesmeasures to protect personal data in accordance with the laws.

 9.5  Club Vcannot recover personal data in cases where:

   o  Improper processing of personal data or fulfillment of the purpose ofprocessing personal data agreed upon by the User;

   o  The storage of personal data is no longer necessary for the operation ofClub V;

   o  Club V is dissolved or ceases to operate or declares bankruptcy or has ourbusiness operations terminated in accordance with laws.

10. Protection of personal data

Club V shall treat Users’ personal data as private and confidential right from the start andthroughout the processing of personal data. Club V shall not disclose Users’personal data to any other party, except in the following cases:

   o  With the consent of the Users;

   o  Users authorize Club V to provide the personal data;

   o  When Club V transfers rights and obligations under the agreement(s) betweenthe Users and Club V;

   o  According to the requirements of relevant competent authorities orcompliance with the laws;

   o  Other cases as prescribed by laws.

11. User’s rights

   o  Users have rights in relation to the personal data as prescribe in DecreeNo. 13. To make enquiries, exercise any of Users’ rights set out above, withdraw Users consent to the processing of Users’ personal data, or make acomplaint against our way of processing of your personal data, please contactus at (84) 903 747 088

   o  In the event that the Users are not satisfied with Club V’s response toyour complaint in relation to the processing of your personal data, Users maysend your complaint to the relevant data protection authority. It is importantthat the Users’ personal data held by Club V is accurate. Please keep Club Vinformed if Users’ personal data changes during the period of processing ofClub V.

12. Withdrawal of consent

   o  Users have the right to withdraw your consent to provide personal data to Club V.

   o  The withdrawal of consent does not affect the lawfulness of the processingof personal data that was consented prior to the withdrawal of consent.

   o  The withdrawal of consent must be expressed in a format that can beprinted, copied in writing, including in electronic or verifiable format.

   o  Upon receiving a request to withdraw consent from Users, Club V shallnotify Users of the consequences and damages that may occur when withdrawing consent.

   o  Upon receipt of notice of withdrawal of consent from Users in accordancewith section 12.3 of this Privacy Policy, Club V must cease and request therelevant organizations and individuals to stop processing the personal data ofUsers.

13. Changes in business ownership and control

   o  Club V may, from time to time, expand or reduce our business, leading tothe involvement of the sale and/or transfer of control of all or part of the Website, personal data provided by Users’ willingness, where it is relevant toany part of Club V’s business, be transferred and the new owner or newlycontrolling party will, under the terms of this Privacy Policy, be permitted touse the personal data for the purposes for which it was originally supplied toClub V.

14. Cookies

   o  When Users visit the Website, cookies are stored on your computer. It ismostly used to make the Website work as Users expect and give you a morepersonalized experience. The Users can accept all or part of cookies on theWebsite.

15. General terms

   o  Users may not transfer any of Users’ rights under this Privacy Policy toany other person. Club V may transfer Club V’s rights under this Privacy Policywhere Club V reasonably believes that Users’ rights will not be affected. Ifany provision of this Privacy Policy (or part of any provision) is invalid,illegal, or unenforceable, that provision or part-provision will be deleted,and the validity and enforceability of the other provisions of this PrivacyPolicy will not be affected.