NOTICE ON PERSONAL DATA PROCESSING

       Moneyveo Vietnam Company Limited is pleased to inform Customers of personal data processing activities as follows:

Definitions:

1.1.         Moneyveo refers to Moneyveo Viet Nam Company Limited, which was legally established and is currently operating under the Enterprise Registration Certificate No. 0316182035 issued for the first time by the Department of Planning and Investment on March 4^th, 2020.

1.2.         Notice refers to the Notice on personal data processing, which is notified to Customers by Moneyveo, regarding their processing of personal data at Moneyveo.

1.3.         Information in the form of symbols, letters, numbers, images, sounds, or equivalences on electronic environment, associated with or used to identify a specific individual. Personal data includes general personal data and sensitive personal data.

1.4.         Personal Data Controller refers to an organization or individual who determines the purposes and means of personal data processing.

1.5.         Personal Data Processor refers to an organization or individual who processes data on behalf of the Personal Data Controller on a basis of a contract or agreement with the Personal Data Controller.

1.6.         Personal Data Controller-cum-Processor refers to an organization or individual who determines the purposes and means of personal data processing and directly processes personal data at the same time.

1.7.         Third party refers to an organization or individual other than the data subject, the Personal Data Controller, the Personal Data Processor, and the Personal Data Controller-cum-Processor who has the authority to process personal data.

Customer consent and Principles of personal data processing

2.1.       Customer consent for data processing pursuant to this Notice is confirmed by a written confirmation, or by voice, or by checking the online consent box on the website “moneyveo.vn, or by consent via text message, or by selecting technical settings that confirm of Customer consent, or other actions showing consent.

The Customer undertakes that the consent in the above forms is completely voluntary, on the basis of knowing clearly the content as prescribed in this Notice.

2.2.      In case the Customer has agreed to let Moneyveo process personal data before the date the Customer confirmed the terms and conditions under this Notice, such a consent will automatically apply in accordance with this Notice without any additional confirmation from the Customer.

Moneyveo's processing of personal data

3.1.      Personal data collection:

Moneyveo (including the Personal Data Processor with which Moneyveo cooperates) may collect Customers’ personal data during its provision of services to Customers and/or when the Customer requests, from a variety of related sources, including but not limited to:

From the information provided to Moneyveo by Customers, when registering to use website services at the website: “moneyveo.vn” and/or according to the Service Contracts or other documents or according to survey programs, promotions organized by Moneyveo that Customers participate in.

Through written and verbal exchanges/communications between the Customer and Moneyveo and/or Third parties that Moneyveo authorized and cooperated with.

From vendors, service providers, partners, merchants and Third parties, including but not limited to surveys, social media, marketing, credit information reference, fraud prevention, data aggregating agencies, infrastructure and facilities support providers, and other third parties in connection with Moneyveo’s business operation.

From third parties connected with Customers, such as their employers, joint account holders, guarantors, security providers, partners, managers.

From any credit reporting agencies, credit reference agencies, and governmental agencies, or information obtained from any publicly available sources.

From the State Bank of Vietnam or other competent authorities in Vietnam or overseas.

Through recorded footage from Closed Circuit Televisions (CCTV) at Moneyveo’s headquarter/ offices.

From analysis conducted by Moneyveo regarding the Customer’s usage of its services.

Via cookies or other similar tracking devices/tools.

From third party sources, where the Customer has consented to the collection, or where collection is required or permitted by the laws and regulations.

3.2.      Processing purposes:

For identity and background establishment; To authenticate and identify the Customer;

To conclude and perform the Service contracts and/or the related previous transactions in order to determine and consult Customers on a suitable loan, in accordance with their needs.

To provide information, offers and conduct marketing/ promotions to Customers in relation to any products or services offered by Moneyveo or its partners, which may be of Customers’ interest.

To conduct a check/verification with the anti-spam, spam email, spam call or other registry (if any);

To implement risk assessment, statistics, trend analysis, and planning purposes, which include the carrying out of data processing and analyses on statistics, credit, risk, and anti-money laundering, in accordance with the laws and regulations;

To assess and process the Customer’s application(s)/request(s) for services provided by Moneyveo;

To provide the service of concluding contracts through remote communication channels in a 24-hour mode;

To implement any other purpose required or permitted by laws and regulations.

3.3.      Types of personal data:

Pursuant to Clause 1, Article 2 of the Decree No. 13/2023/ND-CP, personal data includes general personal data and sensitive personal data.

In accordance with the personal data collection method and the purposes mentioned above, the general personal data which Moneyveo is given consent by Customers to process will include: Full name (named after the customer’s father); Sex; Permanent address and current place of residence; Place of birth; Date, month and year of birth; Nationality; Photo of the Customer’s Identity Card/ ID citizen card, portrait; Tax code and passport information; The link of Customer’s Facebook page; Name and details of work or school; Mobile phone number; Email address; Brand and phone model that the Customer is using; Number of dependents; Academic level; Information about monthly income; Information about other active loans (if any); Reference people information (full name, relationship, phone number); Bank account number & bank name; and Other personal data Bank account number & bank name; and Other personal data in accordance with the laws and regulations, provided to Moneyveo by Customers.

Similarly, the sensitive personal data which Moneyveo is given consent by Customers to process, in accordance with this Notice, will include: Information on customers of credit institutions, foreign bank branches, payment service providers and other licensed institutions, including: customer identification as prescribed by law, accounts, deposits, deposited assets, transactions, organizations and individuals that are guarantors at credit institutions, bank branches, and payment service providers; Personal location identified via location services; and Other specific personal data as prescribed by law that requires specific protection.

3.4.      Personal data processing methods:

On the basis of Customer's contractual obligations with Moneyveo or his/her consent, Moneyveo and/or the Relevant parties shall collect, record, analyze, confirm, store, alter, use, disclose, combine, access, trace, retrieve, encrypt, decrypt, copy, share, transmit, provide, transfer, delete, destroy or conduct any other relevant activities in accordance with the provisions of laws and regulations, in order to fulfill the purposes of this Notice.

The processing of personal data will be implemented flexibly by a combination of automated and non-automated methods.

During the course of the Customer's transactions at Moneyveo's Office and/or through other communication channels such as Moneyveo's hotline, the Customer agrees that Moneyveo will record his/her images and/or voices for the purposes prescribed in this Notice.

3.5.      Relevant parties:

The owner of the processed personal data in accordance with this Notice is Moneyveo; Consequently, Moneyveo has the full right to determine the purpose and means of personal data processing at the website: “moneyveo.vn”.

Moneyveo may process by itself, or provide, in part or in full, the personal data of Clients to Relevant parties to process, for the implementation of the above purposes. Relevant parties shall include:

Moneyveo’s employees;

Any affiliates, owners, organizations, partners, subsidiary companies, which are related to or have a partnership with Moneyveo;

Enterprises acting as suppliers, partners, contractors to provide consultancies, professional advice or to provide other services in connection with, or to support, the operation or business of Moneyveo, including but not limited to companies providing administrative services, postal services, human resource management, data processing, information technology, computers, debt collection, credit information; companies which perform customer identification, market research, record keeping and management, data input,  legal, media, infrastructure, networking, telephony, support technology, workforce management, due diligence, risk reporting.

Any individual, authority, or third party to whom Moneyveo is entitled or obliged to disclose or provide information in accordance with the provisions of law/ at the request of a competent authority, or under any other contract or commitment between Moneyveo and a third party.

3.6.      Potential risks and personal data protection commitment

During data processing, Moneyveo ensures strict legal compliance and data security in order to protect the Customer's personal data at the highest level. However, due to technical reasons or incidents beyond Moneyveo's reasonable control, interruptions, delays, data loss, leakage may still occur; and hence, may cause intended consequences and damages to Clients and/or Moneyveo. In this case, Moneyveo will try its best to repair and strengthen the security barrier, minimize the damage incurred and promptly notify the Customer.

3.7.      Processing term:

Personal data processing will be started as soon as the Customer provides personal data to Moneyveo; and will end when Moneyveo no longer stores any of the above data, in accordance with the Service contract, other agreements with the Customer, Moneyveo's internal regulations, laws and regulations.

3.8.      Disclosure:

Moneyveo will not disclose the personal data of Customers to any other party, except in the following cases:

Under the circumstances specified in this Notice;

When Moneyveo is required or permitted to disclose at the request of a competent State Authority or as required by laws and regulations;

When Moneyveo transfers the rights and obligations in the Service Contract between Moneyveo and the Customer, in accordance with the law;

 When Moneyveo is required to meet its obligations to any relevant regulatory authority.

Rights and Obligations of the Customer

4.1.         Rights of the Customer: Unless otherwise provided by law, the Customer shall have the following rights:

Right to be informed

The Customer has the right to be informed of the processing of their own data unless otherwise stated by the law.

Right to give consent

The Customer has the right to consent to the processing of their data unless such a consent is not required in accordance with the laws and regulations.

Right to access

If necessary, the Customer can request Moneyveo to support and provide their personal data for viewing, rectifying, or requesting rectification of their own personal data in Moneyveo, unless otherwise stated by the law. Such requests of the Customer must be sent to Moneyveo in written form.

Right to withdraw consent

In case the Customer no longer consents to the processing of their personal data, the Customer can withdraw their consent by sending a written request to Moneyveo, unless otherwise stated by the law.

Right to obtain

If necessary, the Customer has the right to request Moneyveo to provide them with their personal data, unless otherwise stated by the law. Other requests of the Customer must be sent to Moneyveo in written form.

Right to delete data

The Customer has the right to request Moneyveo to delete their personal data by sending a written request to Moneyveo, unless otherwise stated by the law. Such request of the Customer must be sent to Moneyveo in written form.

Right to restrict processing

Unless otherwise stated by the law, the Customer has the right to restrict Moneyveo from processing their personal data, and the request must be sent to Moneyveo in written form. If the request is within the capacity of Moneyveo and complies with regulations of the law, within 72 hours of receiving the valid request from the Customer, Moneyveo will take actions in compliance with the law and internal regulations of Moneyveo to restrict the processing of personal data as requested by the Customer

Right to object

In case the Customer wishes to prevent or restrict the disclosure of personal data or the use of personal data for advertising and marketing purposes, the Customer has the right to object to Moneyveo and/or related Parties’ processing of their personal data, unless otherwise stated by law. The objection of the Customer must be sent to Moneyveo in written form. If the request is within the capacity of Moneyveo and complies with regulations of the laws and regulations, within 72 hours of receiving the valid request from the Customer, Moneyveo will take actions in compliance with the law and internal regulations of Moneyveo to fulfill the request of the Customer, unless otherwise stated by the law.

Right to file complaints, denunciations, and lawsuits

The Customer has the right to file complaints (to Moneyveo), denunciations, and lawsuits as prescribed by the laws and regulations.

Right to claim damage

The Customer has the right to claim compensation for the damages as prescribed by the law in case the personal data protection regulations are violated unless Moneyveo and the Customer have agreed on other compensation terms for specific products and services.

Right to self-protect

The Customer has the right to self-protect according to relevant regulations, or request competent agencies and organizations to take civil rights protection measures according to regulations in Article 11 of the Civil Code

4.2.         Obligations of the Customer: Unless otherwise provided by law, the Customer shall have the following obligations:

Protect their own personal data and request relevant organizations and individuals to protect their personal data.

Respect and protect others’ personal data.

Fully and accurately provide their personal data to Moneyveo and/or the related Parties who are involved in the processing of the Customer’s personal data and allowed to do so by the Customer

Participate in the dissemination of personal data protection skill

Comply with regulations of the law on protection of personal data and prevent violations against regulations on protection of personal data.

In case the Customer provides the personal data of another individual to Moneyveo and/or the related Parties, the Customer must have that data subject’s consent to provide such data, and Moneyveo is fully exempt from the responsibilities of such actions.

For the avoidance of doubt, in case the Customer provides personal data relating to a third party (including but not limited to information of dependents, related persons as prescribed by law, spouse, children and/or parents, and/or guardians, beneficiaries, attorneys, partners, emergency contacts, etc.) to Moneyveo, the Customer represent and warrant that the consent of that third party has been obtained for the processing of the personal data, and that the third party has been noticed that Moneyveo is the Data Processor for the purposes listed in this Notice.

 In case the Customer has a written request for consent withdrawal and/or requests Moneyveo to delete the data or restrict processing of the Customer’s personal data, Moneyveo has the right to limit or stop providing services to the Customer because Moneyveo does not have sufficient data or information to provide services to the Customer. In this case, Moneyveo is not responsible for any losses on the Customer's side.

No complaints or lawsuits shall be filed against Moneyveo for the content implemented by Moneyveo as agreed upon by the Customer pursuant to this Notice.

Rights and Obligations of Moneyveo

5.1.         Rights of Moneyveo:

Moneyveo has the right to process the Customer’s personal data once the Customer has given consent pursuant to this Notice.

Moneyveo has the right to request full and accurate personal data of the Customer, according to this Notice.

Moneyveo has the right to decline the written request of the Customer to withdraw consent, access, erase, restrict processing, provide, and object to the processing of the Customer’s personal data, in accordance with laws and regulations.

Moneyveo is exempt from the obligations and responsibilities in case the Customer provides the personal data of another individual to Moneyveo and/or the related Parties without consent from that data subject.

Moneyveo has the right to provide and disclose the Customer’s personal data to other parties described in this Notice.

In case the Customer has a written request for consent withdrawal and/or requests Moneyveo to delete the data or restrict processing of the Customer’s personal data, Moneyveo has the right to limit or stop providing services to the Customer because Moneyveo does not have sufficient data or information to provide services to the Customer. In this case, Moneyveo is not responsible for any losses on the Customer's side.

To fulfill the purpose of processing personal data as prescribed in article 3.2. of this Notice, Moneyveo may provide/transfer Customers' personal data to Moneyveo’s related third parties, and these third parties may be located in Vietnam or any other location outside the territory of Vietnam.

Other rights as prescribed by the laws and regulations.

5.2.         Obligations of Moneyveo:

Carry out protection measures for the Customer personal data Moneyveo currently has, as prescribed by the laws and regulations.

Comply with the regulations of the law on Customer personal data protection.

Contact:

-          Custom service center: 1800646475

-          Address: 21 Nguyen Trung Ngan Street, Ben Nghe Ward, District 1, Ho Chi Minh City, Viet Nam:

This notice is made in English for reference purpose only. In case of conflict between the English and Vietnamese versions, the Vietnamese one will prevail. 

Issuance date: 01/07/2023