PRIVACY POLICY

1. General provisions

This Personal data processing Policy is compiled in strict accordance with the Regulations of Vietnam (hereinafter referred to as the ROV), international law on the collection, processing, protection, and use of personal data. As generally accepted rules on the processing, storage, and transfer of personal data on the Internet and other legal acts governing the processing, storage, and transfer of personal data on the Internet and defines the procedure for processing personal data and measures to ensure the security of personal data taken https://proxyipusvn.com (hereinafter referred to as the Operator).

    • 1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of man and citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.
    • 1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about website visitors https://proxyipusvn.com.
  2. Basic concepts used in the Policy
    • 2.1. Automated processing of personal data – processing of personal data using computer technology.
    • 2.2. Blocking of personal data – temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data).
    • 2.3. Website – a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at a network address https://proxyipusvn.com.
    • 2.4. Personal data – any information or set of information related to an identified or specifically identifiable individual.
    • 2.5. Personal data information system — a set of personal data contained in databases, and information technologies and technical means that ensure their processing.
    • 2.6. Depersonalization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the identity of personal data to a specific User or other subject of personal data.
    • 2.7. Personal data processing – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
    • 2.8. Personal data authorized by the subject of personal data for distribution – personal data to which an unlimited number of persons have access by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in accordance with the procedure provided for by the ROV (hereinafter – personal data authorized for distribution).
    • 2.9. User – any visitor to the website https://proxyipusvn.com.
    • 2.10. Provision of personal data – actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
    • 2.11. Dissemination of personal data – any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data of an unlimited circle of persons, including the publication of personal data in the media, placement in information and telecommunications networks or providing access to personal data in any other way.
    • 2.12. Cross–border transfer of personal data – transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual or a foreign legal entity.
    • 2.13. Destruction of personal data – any actions as a result of which personal data is permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the material carriers of personal data are destroyed.
  3. Basic rights and obligations of the Operator
    • 3.1. The Operator has the right to:
      • receive reliable information and/or documents containing personal data from the subject of personal data;
      • if the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the ROV, international law on the collection, processing, protection, and use of personal data;
      • independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the ROV, international law on the collection, processing, protection, and use of personal data.
    • 3.2. The Operator is obliged to:
      • provide the subject of personal data, at his request, with information concerning the processing of his personal data;
      • organize the processing of personal data in accordance with the procedure established by the current legislation of the country of the Operator;
      • respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the GDPR;
      • to inform the authorized body for the protection of the rights of personal data subjects at the request of this body of the necessary information within 30 days from the date of receipt of such a request;
      • publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
      • take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions with respect to personal data;
      • stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by ROV;
      • perform other duties provided for by ROV.
  4. Basic rights and obligations of personal data subjects.
    • 4.1. Personal data subjects have the right to:
      • access their personal data and information about how this personal data is being processed;
      • request erasure of personal data related to them on any one of a number of grounds;
      • object to processing personal information for marketing or non-service related purposes;
      • receive compensation from the Operator for the damage suffered;
      • to exercise other rights provided for by the ROV.
    • 4.2. Personal data subjects are obliged to:
      • provide the Operator with reliable data about themselves;
      • inform the Operator about the clarification (update, change) of their personal data.
    • 4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter’s consent are liable in accordance with the legislation of the country of the Operator.
  5. The Operator may process the following personal data of the User:
    • 5.1. Surname, first name, patronymic.
    • 5.2. Email address.
    • 5.3. Phone numbers.
    • 5.4. Also on site is the collection and processing of anonymous data about visitors (including cookies) using Internet statistics (Yandex Metric and Google Analytics and others).
    • 5.5. The above data, hereinafter referred to in the text of the Policy, are combined by the general concept of Personal Data.
    • 5.6. Processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.
  6. Principles of personal data processing:
    • 6.1. if the data subject has given consent to the processing of his or her personal data;
    • 6.2. to fulfill contractual obligations with a data subject, or for tasks at the request of a data subject who is in the process of entering into a contract;
    • 6.3. to comply with a data controller’s legal obligations;
    • 6.4. to protect the vital interests of a data subject or another individual;
    • 6.5. to perform a task in the public interest or in official authority;
    • 6.6. for the legitimate interests of a data controller or a third party, unless these interests are overridden by interests of the data subject or her or his rights according to the Charter of Fundamental Rights.
  7. Purposes of personal data processing
    • 7.1. Personal data is processed by the Operator for providing and improving services; managing account and providing customer support; researching and analysing of Service usage; communication with the User via email; developing, displaying, and tracking content and advertising; service Analysing;
    • 7.2. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an email to the Operator cs@proxyipusvn.com marked “Refusal of notifications about new products and services and special offers”.
    • 7.3. Depersonalized User data collected using Internet statistics services are used to collect information about User actions on the site, improve the quality of the site and its contents.
  8. Legal grounds for processing personal data
    • The legal grounds for processing personal data by the Operator are:
      • ROV;
      • statutory documents of the Operator;
      • contracts concluded between the Operator and the subject of personal data.
    • The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://proxyipusvn.com or sent to the Operator via e-mail. By filling out the appropriate forms and/or sending their personal data to the Operator, the User agrees with this Policy.
    • The Operator processes depersonalized data about the User if this is allowed in the User’s browser settings (the saving of cookies and the use of JavaScript technology are enabled).
    • The subject of personal data independently decides on the provision of his personal data and gives consent freely, of his own free will and in his own interest.
  9. Terms of personal data processing
    • The processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.
    • The processing of personal data is necessary to achieve the goals stipulated by international agreements of the country of the Operator, to carry out the functions, powers and duties assigned to the operator by the legislation of its country.
    • The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the country of the Operator on enforcement proceedings.
    • The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
    • The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
    • Processing of personal data is carried out, access of an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).
    • Processing of personal data subject to publication or mandatory disclosure in accordance with ROV is carried out.
  10. Procedure for the collection, storage, transfer and other types of personal data processing.

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

    • 10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to the personal data of unauthorized persons.
    • 10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
    • 10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator’s email address cs@proxyipusvn.com marked “Updating of personal data”.
    • 10.4. The term of personal data processing is determined by the achievement of the purposes for which personal data was collected, unless another term is stipulated by the contract or the current legislation.
    • 10.5. The User may withdraw his consent to the processing of personal data at any time by sending a notification to the Operator via e-mail to the Operator’s e-mail address cs@proxyipusvn.com marked “Withdrawal of consent to the processing of personal data”.
    • 10.6. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their Public Offer and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
    • 10.7. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing of personal data in the state, public and other public interests defined by the legislation of the country of the Operator.
    • 10.8. When processing personal data, the Operator ensures the confidentiality of personal data.
    • 10.9. The Operator stores personal data in a form that allows determining the subject of personal data, no longer than the purposes of personal data processing require, unless the period of personal data storage is established by ROV, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
    • 10.10. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the identification of unlawful processing of personal data.

     11. List of actions performed by the Operator with the received personal data

    • 11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data.
    • 11.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

     12. Cross-border transfer of personal data

    • 12.1. Before the start of the cross-border transfer of personal data, the Operator is obliged to make sure that the foreign state to whose territory the transfer of personal data is supposed to be carried out provides reliable protection of the rights of personal data subjects.
    • 12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements may be carried out only if there is written consent of the personal data subject to cross-border transfer of his personal data and/or execution of the contract to which the personal data subject is a party.

     13. Confidentiality of personal data

The operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by ROV.

      14. Final provisions

    • 14.1. The User can receive any clarifications on issues of interest concerning the processing of his personal data by contacting the Operator via e-mail cs@proxyipusvn.com.
    • 14.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
    • 14.3. The current version of the Policy is freely available on the Internet at https://proxyipusvn.com/privacy-policy.

Company details:

VINPOS CO. LTD.

Company name: VINPOS CO. LTD.
Company Number: 0317400141
VN Office: 108/60C Tran Quang Dieu, Ward 14, District 3, Ho Chi Minh City
US Office: 33137 Ave Apt 1119, Miami, Florida