PRIVACY POLICY

1. Introduction

Welcome to (the) products, services, applications, websites operated by Red Circle Co., Ltd. and its subsidiaries, affiliates, and affiliated companies of Red Circle Co., Ltd. (individually and collectively referred to as “CKVN” or “We”). CKVN is committed to responsibly handling your information security in accordance with legal regulations.

THIS PRIVACY POLICY (“Policy”) is designed to help you understand how we process your Personal Data that you provide to CKVN and to help you make informed decisions before providing any of your Personal Data. Additionally, this Policy serves as a notice of personal data processing sent to you before we process your Personal Data. In the event CKVN changes the Policy, we will post those changes on the Website and Applications. CKVN reserves the right to amend, supplement this Policy at any time without prior notice to you.

“Platform” means the applications (“Applications”) and/or website (“Website”) of CKVN.

“Products, Services” means the goods, services provided by us as described in CKVN’s Platform.

“Personal Data” means information in the form of signs, letters, numbers, images, sounds, or similar forms in the electronic environment that are linked to you or help identify you. Personal Data provided by you and you are responsible for the accuracy of the data.

“Processing Personal Data” means one or more activities affecting your Personal Data, such as: collecting, using, recording, analyzing, verifying, storing, editing, disclosing, combining, accessing, retrieving, recovering, encrypting, decrypting, copying, sharing, transmitting, providing, transferring, deleting, destroying Personal Data or other related actions.

By registering an account with CKVN on the Platforms or accessing the Applications or Website, you agree to us Processing your Personal Data and accept the contents, practices described in this Policy.

IF YOU DO NOT AGREE TO ALLOW THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS POLICY, PLEASE IMMEDIATELY CEASE ACCESSING OUR APPLICATIONS OR WEBSITE.

 

2. When CKVN collects data

2.1 CKVN will/may collect data about you:

a) When you access CKVN’s Platform, register an account, and/or perform transactions through CKVN’s Applications or Website (e.g., purchasing goods).

b) When you submit any forms, including but not limited to registration forms or other forms related to any CKVN Products, Services, online or otherwise.

c) When you interact with us through various communication channels, including but not limited to Applications, Websites, telephone (may be recorded), mail, fax, direct meetings, social media platforms, and email.

d) When you provide feedback or submit complaints to CKVN.

e) When you register to participate in a contest or participate in promotional programs.

f) When you submit your data to CKVN for any reason.

The above are some common cases in which CKVN collects your data, not reflecting all cases in which CKVN will collect data.

2.2 In some cases, you may provide Personal Data of other individuals to us. If you provide us with their Personal Data, you declare and warrant that you have obtained their consent to process their Personal Data under this Policy.

 

3. Types of data collected and processed

We may collect one or more types of data, including but not limited to basic Personal Data and sensitive Personal Data, specifically as follows:

3.1 Full name; Email address; Date of birth; Gender; Phone number.

Billing and/or shipping address; bank account and payment information.

3.2 Information about the number of visits, pages you view, links you access, and other information related to your connection to our Website and Applications.

3.3 Images collected from surveillance camera systems.

3.4 Access data: Information automatically collected by our server when you access the Platform, such as your original actions inseparable from the Application, including: entering verification codes, search results, likes, saves, or replies to a post, as well as other interactions with the Application and other users through server log files.

3.5 Shopping information: To perform upgrade the tier according to the general policy, the Platform will collect information about your purchases to integrate enough requirements to upgrade to Silver; Gold member levels. As a result, you will enjoy preferential policies depending on each member level.

3.6 Financial data: During transactions, you may choose non-cash payment methods to purchase goods. Any financial information related to your payment (e.g., valid credit card number, card brand, expiration date) is stored only on the payment processor of the payment service provider (bank or intermediary payment service organization). However, to perform statistical analysis including trend analysis, adjust Products, Services, perform risk assessment, and analyse costs related to Platform operations, we may collect data about the number of times, amounts, and other statistics from these partners transferred to us under a service contract between the two parties for payments through bank account/intermediary payment service organization. However, all the data above is anonymized to ensure that you cannot be detected or identified from that information.

3.7 Access Rights to Personal Information on Facebook Account: By default, the application may access your basic Facebook account information as well as other information you choose to make public. The application may also request access to additional permissions related to your account, such as friends list, subscriptions, and likes. You can choose to allow or deny the application access to each individual permission.

3.8 Mobile Device Access Rights: The application may require access or permissions for certain features from your mobile device, including bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage, and other mobile device features. If you wish to change the access or permissions of the application, you can do so by resetting your device settings.

3.9 Mobile Device Data: Device information such as mobile device ID, model, manufacturer, operating system version, phone number, country, your location, and any other data you agree to provide.

3.10 Data from contests, gifts, and surveys: Personal information and other information you may provide when participating in contests, gifts, or responding to surveys.

3.11 Any other information about you when you log in to use CKVN’s Platform, information about how you use CKVN’s Platform.

 

4. CKVN may Process Your Personal Data for one or more of the following purposes:

4.1 Processing account registration applications and executing transactions with Us, including but not limited to purchasing Products, Services, participating in promotional programs, receiving rewards.

4.2 Managing and operating your use and/or access to the Platform, your preferences, and the relationship between your account and Us.

4.3 Responding to, processing, resolving, or completing a transaction and/or responding to your requests for Products, Services, including but not limited to resolving or answering any queries.

4.4 Notifying you of service issues as well as abnormal account activities.

4.5 Enforcing our terms of service or any applicable agreement, terms of use at the Platform.

4.6 Identifying, verifying, and/or protecting your safety and that of others.

4.7 Maintaining and managing any software/application updates.

4.8 Conducting research, analysis, and development activities (including, but not limited to, data analysis, surveys, developing and/or establishing Product and Service characteristics), to analyse how you use Products, Services to improve Products, Services and/or enhance user experience.

4.9 Advertising, surveys, marketing, and promotion related to Products, Services (including, but not limited to products and/or services of third parties that CKVN may collaborate or associate with). You may receive regular SMS messages and emails about new products, new services, special promotions, and/or upcoming events such as: contests, anniversaries, … We may use surveys to consult your opinion about current services or potential new services.

4.10 Complying with legal procedures, complying with regulations of law and requests from competent authorities.

4.11 Establishing statistics and studies in response to reporting requirements and/or maintaining internal books.

4.12 Or any other purposes that We notify you at the time of requesting your permission.

 

5. Time of Processing Personal Data

The Processing of Personal Data will be carried out from the time the data is collected until you request cancellation or log in and carry out cancellation or CKVN has reasonable grounds to determine that (i) retaining that Personal Data no longer serves the purpose of collecting that Personal Data; (ii) retention is no longer necessary for any legitimate or business purpose and (iii) there are no other legitimate benefits to continue retaining this Personal Data and/or any other case under the law. If you stop using CKVN’s Platform, We may continue to Process Your Personal Data in accordance with this Policy and other current legal regulations.

 

6. Organizations, individuals processing data and/or related to the purpose of Processing Personal Data

In the course of conducting business operations, We will/may need to use, process, disclose and/or transfer Your Personal Data to third-party service providers, agents and/or Our affiliated companies or related companies, and/or other third parties for one or more purposes mentioned in Article 4, and such disclosure will be made in accordance with the proper procedure and regulations of current law. We endeavor to ensure that third parties and Our affiliated companies keep Your Personal Data secure from unauthorized access, collection, use, disclosure, unlawful processing or similar risks and only retain Your Personal Data as long as Your Personal Data is still necessary for the purposes mentioned in Article 4. Such third parties include: (i) parent companies, subsidiaries, affiliates and related companies of Red Circle Co., Ltd. and/or the Circle K brand; (ii) contractors, agents, service providers, and other third parties that We hire to support or supplement Our business operations, including but not limited to reliable partners to help Us advertise, build the Platform, develop e-commerce, analyse data statistics, send emails or postcards to you, support or arrange delivery arrangements, and (iii) any individual, authority, management agency, or third party that CKVN is authorized or required to disclose as stipulated by law or by any other contract or commitment between the third party and CKVN.

 

7. Data security and potential unintended consequences/damages

7.1 CKVN commits to ensuring the security of your data, absolutely not buying, exchanging your information with third parties for commercial purposes. In case the server storing information is attacked by hackers leading to loss of your data, We will be responsible for notifying the incident to the investigating authorities for timely processing and informing you.

7.2 CKVN commits that all information you provide is stored in Our customer data will not be shared with any individual or business, except as provided in Article 6 of this Policy. However, if you choose to participate in multiple related activities on the Platform, such as chatting, posting in the comment section or in Our forum, liking posts, providing feedback and responding to surveys, meaning you voluntarily disclose your personal information through your profile, online chat or other interactive areas of the Platform, please note that all information you disclose in these areas is public and your information may be accessed by anyone logged into the Platform, not just Us and therefore this information will not fall within the scope of confidentiality commitment under this Policy.

7.3 Processing of Personal Data may pose risks of data leakage or improper data handling. Understanding the importance of protecting Personal Data, CKVN considers information as its valuable asset and therefore implements various measures to ensure the security of your Personal Data. CKVN regularly reviews and updates management and technical measures when Processing Personal Data.

 

8. Your rights and obligations regarding collected data

8.1 Your obligations: Provide, update fully, accurately Personal Data when consenting to CKVN processing your data.

8.2 Except as otherwise provided by law, you have the following rights:

a) Right to know: You have the right to know about your Personal Data Processing activities.

b) Right to consent: You have the right to consent or refuse consent to the Processing of your Personal Data.

c) Right to withdraw consent and restrict data processing: You have the right to withdraw your consent or request CKVN to restrict Processing of your Personal Data. If you (i) withdraw consent regarding the collection, use, and disclosure of your personal information, or (ii) request CKVN to restrict Processing of Personal Data, such actions may lead to limitations, restrictions, temporary suspension, cancellation, prevention, or prohibition of the contract/agreement between you and CKVN, as applicable. CKVN shall not be liable to you for any resulting losses. CKVN also reserves its legal rights related to such limitations, restrictions, temporary suspension, cancellation, prevention, or prohibition.

d) Right to access/query and provide data: You have the right to access/query to view, edit, or request CKVN to edit your Personal Data, and have the right to request CKVN to provide your Personal Data.

e) Right to delete data: You have the right to delete or request CKVN to delete your Personal Data in cases where (i) you find it no longer necessary for the purposes set out in Article 4 and accept the potential damage that may occur when requesting data deletion, (ii) you withdraw consent, (ii) you object to the data processing and CKVN has no legitimate reason to continue processing; (iii) you have evidence that CKVN processes data incorrectly for the purposes set out in Article 4 or violates legal provisions. To clarify, the right to delete data shall not apply in certain cases as stipulated by relevant laws.

f) Right to object to data processing: You have the right to object to data processing to prevent or restrict CKVN from disclosing Personal Data or using it for advertising or marketing purposes.

g) Right to complain, report, file lawsuits, request compensation for damages, and defend oneself: In case you have evidence that CKVN violates commitments under this Policy, you shall notify CKVN to cease the violation, and both parties shall agree on appropriate remedial measures. If CKVN does not cease the violation within 60 working days from the date both parties begin negotiating remedial measures, you have the right to:

• Lodge a complaint, report, or file a lawsuit with the competent authority;

• Request compensation for actual and direct damages incurred as a result of CKVN’s violation of provisions under this Policy. You need to provide evidence of the damages. To avoid confusion, CKVN shall not be responsible for any losses and/or indirect costs that you may incur or any responsibility you have towards any third party; and/or

• Defend oneself or request competent authorities, organizations to implement civil rights protection measures as stipulated by relevant laws.

8.3 CKVN shall fulfill your requests related to providing, accessing/querying, editing, deleting Personal Data or restricting, objecting to Processing of your Personal Data within 72 hours upon receiving a complete and valid request from you. Associated costs (if any) shall be borne by you, based on the rates determined by CKVN, in accordance with practicalities and legal regulations.

 

9. Links

The CKVN Platform may display links to third-party websites, software applications, or mobile applications (“Third-Party Links”) owned, controlled, or provided by third parties. Accessing and using such Third-Party Links shall be governed by the terms and conditions applicable to such access and/or use, with all risks entirely borne by you. To avoid confusion, when creating a link to Third-Party Links, CKVN shall not be understood as endorsing or recommending the use of any products or services provided or not understood as verifying any information available on Third-Party Links. Therefore, CKVN shall not be liable for any and all information, documents, products, or services (or the absence of such information, documents, products, or services) available on or provided at the connected Third-Party Links. Additionally, we do not assume any responsibility for the security measures (or lack thereof) and activities of these Third-Party Links. However, we strive to protect the integrity of the CKVN Platform and links placed on each respective Platform, and therefore, CKVN welcomes feedback on these Third-Party Links.

 

10. Contact

You may exercise your rights by sending requests to CKVN via the following information:

• Address: 160 Bui Thi Xuan, Pham Ngu Lao Ward, District 1, Ho Chi Minh City, Vietnam

• Phone: 028.3620 9017 or 1900 3110

• Email: [email protected]