2. COLLECTION OF PERSONAL DATA

a. We collect various types of personal data about you, including but not limited to:

Contact Data: Such as your mailing or home address, location, email address, and mobile phone number.

Identity and Profile Data: Such as your name, username or similar identifiers, photos, and gender.

Marketing and Communications Data: Such as your email address, information posted in service requests, offers, preferences, feedback, comments, images, and discussions in our blog and chatbox, responses to surveys and user polls, your preferences in receiving marketing information from us and our third parties, and your notification preferences. We also collect records of your conversations and calls when you communicate with our customer service representatives through the app.

Technical Data: Including IP address, browser type, internet service provider, details of the operating system, access time, page views, device ID, device type, frequency of visiting our website and using the Platform, website and mobile application activity, clicks, dates and times, location data, and other technology on the devices you use to access the Platform.

Transaction Data: Such as details about the Services you have used, limited details of your credit or debit card to track transactions provided to us by the payment processor, and UPI ID to process payments.

Usage Data: Including information about how you use the Services, your activities on the Platform, booking history, user clicks and presses, user preferences, time spent on the Platform, details about your journey on the mobile application, and page views.

b. We also collect, use, and share aggregated data such as statistical or demographic data for any purpose:

Aggregated data may be derived from your personal data but is not considered personal data by law as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data that will be used in accordance with this Policy.

c. What happens if I refuse to provide my personal data?

When we need to collect personal data by law or under the terms of a contract (such as the Terms) and you do not provide that data when requested, we may not be able to fulfill the contract (e.g., provide you with the Services). In this case, we may have to cancel or restrict your access to the Services.

3. HOW DO WE COLLECT PERSONAL DATA?

We use different methods to collect personal data from and about you through:

a. Direct interactions

You provide us with your personal data when you interact with us. This includes personal data you provide when you:

• Complete user profiles or registration forms
• Use our Services or engage in other activities related to the Services
• Participate in promotions, user polls, or online surveys
• Request marketing information to be sent to you
• Report issues with our Platform and/or Services, provide feedback, or contact us

b. Automated technologies or interactions

Each time you access the Platform or use the Services, we automatically collect Technical Data about your device, browsing actions, and patterns. We collect this personal data using cookies, web beacons, pixel tags, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites or applications employing our cookies.

c. Third parties or publicly available sources.

We will receive personal data about you from various third parties:

• From analytics providers like Facebook, Google Analytics, and advertising networks
• From customer service representatives performing services
• From other customers where they provide information about you to us, such as through customer referrals
• From publicly available sources and other third-party data providers
• From our affiliates

4. HOW DO WE USE YOUR PERSONAL DATA?

a. We use personal data for any legitimate purposes.

Most commonly, we will use your personal data when we need it to perform or provide the Services, enable you to use the Services, or when we need to comply with a legal obligation, including but not limited to the following purposes:

⁃ Providing Services and Features

Your Personal Data will be used to provide, personalize, maintain, and improve our Applications, Websites, and Services. This includes using your Personal Data to:

• Interact with you to provide Services across our various business areas.
• Create, administer, and update your account.
• Process, manage, or verify the execution of Services, offers, rewards, and subscriptions with NTSpace.
• Conduct due diligence checks and risk assessments/analyses.
• Verify your identity and age (when necessary).
• Suggest, obtain, provide, facilitate, or maintain insurance or financial solutions.
• Personalize your Application experience (e.g., recommending products or services that may be relevant to you, determining your preferences, or personalizing your experience with NTSpace).
• Make your experience seamless, such as auto-filling your registration information (like your name or phone number) from one Service to another or when participating in our surveys.
• oConduct necessary internal activities to provide the Services, including troubleshooting software and operational issues, conducting data analysis, testing and research, monitoring and analyzing usage and activity trends.
• Protect the security or integrity of the Services and any means or devices used to provide the Services.
• Enable communication between our users.
• Invite you to participate in our surveys and research.
• Allow our partners to manage and allocate resources.
• Provide services to you as a Data Processor, as you have agreed with the Data Controller (e.g., the organization you have purchased goods or services from, and NTSpace is providing those services on behalf).

⁃ Safety and Security

We use your data to ensure the safety and security of our Services and all users. This includes:

• Screening service providers before allowing them to use our Services.
• Verifying your identity when you log into NTSpace.
• Using device, location, profile, usage, and other Personal Data to prevent, detect, and combat fraud or unsafe activities.
• Monitoring compliance with our terms and conditions and policies.

Customer Support

We use Personal Data to resolve customer support issues.

For example, we may:

• Investigate and address concerns.
• Monitor and improve our customer support responses.
• Respond to questions, comments, and feedback.
• Inform you of actions taken to resolve support issues.

⁃ Research, Development, and Security

We may use the Personal Data we collect for testing, research, analysis, and product development. This allows us to understand and analyze your needs and preferences, protect your personal data, improve and enhance the safety and security of our Services, develop new features, products, and services, and facilitate the development of financial and insurance solutions.

⁃ Legal Purposes

We may use the Personal Data we collect for legal purposes, such as investigating and resolving claims or disputes, detecting/preventing/prosecuting crime, or when permitted or required by applicable law. We may also use your Personal Data when advised, requested, demanded, or instructed to do so by our legal advisors or any applicable law, regulation, government, or local authority.

For example, we may use your Personal Data to:

• Comply with court orders or other legal, governmental, or regulatory requirements.
• Enforce our Terms of Service or other agreements.
• Protect our rights or property in case of claims or disputes.

⁃ Marketing and Communications

We may use your Personal Data to send you marketing information about personalized products or services (which you may find interesting or relevant based on your account information) or from NTSpace’ sponsored partners, and advertisers about products, services, events, or promotions. For example, we may:

• Send you special offers that you may find interesting or relevant through NTSpace service recommendations.
• Send you notices, newsletters, updates, emails, promotional materials, privileges, and festive greetings.
• Notify, invite, and manage your participation in our events or activities.

We may communicate such marketing to you through various means, where appropriate, including messages, chat applications (e.g., WhatsApp, Telegram, LINE, Viber, WeChat, Zalo), push notifications, calls, and emails.

If you wish to unsubscribe from receiving such marketing information, please click the unsubscribe link in the relevant email or message. Additionally, you can update your preferences in the Application settings. Please note that after you have unsubscribed from marketing or promotional programs, NTSpace may still send you service-related messages (such as information about your transactions, rewards, etc.).

⁃ User-Provided Public Content

If you publicly post certain content (such as reviews or comments) on the NTSpace platform, it will be viewed publicly along with your Personal Data (e.g., account name, uploaded images, and other information you included in your content).

b. We may use and share anonymized or aggregated information for any legitimate purposes.

5. COOKIES, DIGITAL ADVERTISING, AND ANALYTICS

a. NTSpace and third parties

NTSpace and third parties we partner with may use cookies, web beacons, tags, scripts, data-sharing objects like HTML5, advertising identifiers, and similar technologies (collectively referred to as “Cookies”) in connection with your use of the Websites and Applications. These Cookies may be persistent or stored only during an individual session on your browser or device.

Cookies can contain unique identifiers and reside, among other places, on your computer or mobile device, in emails we send you, and on our web pages. Cookies may be used for various purposes such as:

• Providing essential features and functionality for using our Websites, Services, and Applications;
• Authenticating you or remembering your settings and user preferences;
• Communicating and measuring the effectiveness of advertising campaigns, such as by counting the number of views or visits;
• Analyzing website traffic and trends;
• Delivering relevant advertisements to you on other applications and websites (whether owned by us or other advertisers);
• Enhancing the user interface and experience by understanding general user behavior and preferences interacting with our Website, Services, and Applications.

NTSpace may allow third parties to use Cookies on the Websites and Applications to collect the same type of Personal Data for the same purposes NTSpace does. These third parties may link the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

b. Digital Advertising

We may facilitate the display of Targeted Ads on other platforms, such as other online platforms you may use. Some of these ads may be personalized, meaning they are intended to be relevant to you based on information the advertising provider collects about your use of websites or applications over time, including information about relationships among different browsers and devices. This type of advertising is called interest-based advertising. Note that opting out will not prevent ads from appearing in your browser or applications. It may make the ads you see less relevant to your interests.

6. DISCLOSURE OF YOUR PERSONAL DATA

We need to share Personal Data with various parties for several purposes. These parties include:

⁃ Other Users

• If you are a customer, we may share your username and service location with our service providers to fulfill your service request.
• If you are a service provider, we may share your Personal Data with your customers, including your name and photo; background information, work experience, location, and average rating.
• If you use the in-app chat service, we may share your phone number and NTSpace registration name with others involved in your chat.

- Third Parties

⁃ With third parties related to your use of NTSpace Services.

⁃ Subsidiaries and Affiliates

We share Personal Data with our affiliated companies and entities under common control. For example, this ensures a seamless experience, such as auto-completing your registration information when you sign up for a new NTSpace Service.

⁃ Service Providers and Business Partners of NTSpace

We may provide Personal Data to suppliers, consultants, marketing partners, research firms, and other service providers or business partners. This includes:

• Payment processors and facilitators;
• Debit collection agencies;
• Credit bureaus and other credit reporting agencies;
• Background check and anti-money laundering service providers;
• Cloud storage providers;
• Advertising and marketing partners and platform providers;
• Data analytics providers;
• Research partners, including those conducting surveys or research projects in partnership with or on behalf of NTSpace;
• Educational and training partners;
• Merchant and transportation partners;
• Insurance and financial partners;
• Third-party intermediaries involved in managed investments of funds, such as brokers, asset managers, and custodians;
• Service providers performing identity verification services.

⁃ Our Legal Advisors and Government Authorities

We may share your Personal Data with legal advisors, law enforcement officials, government authorities, and other third parties. This may be done to fulfill legal purposes (mentioned above) or in any of the following cases:

• When it is necessary to respond to an emergency that threatens the life, health, or safety of an individual; or
• When it is necessary in the public interest (e.g., in a public health crisis, for contact tracing purposes, and protecting our community).

7. YOUR CHOICES REGARDING PERSONAL DATA

a. Accessing and Updating Personal Data:

It is important that the personal data we hold about you is accurate and up-to-date. When you use our Services, we provide you with the ability to access and correct inaccurate or incomplete data, subject to any legal requirements. If your personal data changes, please update this information or contact us for assistance in doing so.

b. Opting Out of Marketing and Advertising Communications:

When we send you marketing and advertising content, such as via email or, if you have agreed, via SMS or text messages, we provide you with the ability to opt out of receiving such communications. Please note that even if you opt out, we may still send you emails about your user account or any Services you have requested or received from us.

8. TRANSFER OF PERSONAL DATA

a. We comply with applicable laws regarding the storage and transfer of personal data. As part of using the Services, the personal information and data you provide to us may be transferred to and stored in countries different from your country of residence. This may occur if any of our servers are located in a country different from your country of residence or if one of our suppliers, partners, or service providers is located in a country different from your country of residence.

b. By submitting your personal information and data to us, you understand that such information and data will be transferred, stored, and processed as described above.

9. DATA SECURITY

a. We implement appropriate security measures and privacy protections on our Platform, including encryption, password protection, call masking, and physical security measures designed to protect personal data from unauthorized access and disclosure, in accordance with the standards required by applicable laws.

b. However, no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. Additionally, you should be aware that data transmission over the internet is not always secure, and we cannot guarantee that information you transmit using the Services or Platform is or will be secure.

c. If you have chosen a password that enables you to access certain parts of the Services, you are responsible for keeping this password confidential and secure. We will not be responsible for any unauthorized use of your information, any lost, stolen, or compromised passwords, or for any activity on your user account due to unauthorized password use or disclosure. If your password is compromised in any way, you should notify us immediately so we can change your password.

10. DATA STORAGE

a. We store and retain personal data for as long as necessary to fulfill our stated purposes, including for a reasonable period after your account on the Platform has been terminated or your access to the Services has been revoked, in order to comply with our legal rights and obligations.

b. In some circumstances, we may anonymize or aggregate personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

11. USER-GENERATED CONTENT

We invite you to post content on our Platform, including comments, feedback, photos, or any other information you wish to share on our Platform. Please be aware that such content may be posted publicly and visible to visitors of our Platform.

12. POLICY UPDATES

NTSpace may revise, update, or amend the terms of this Privacy Policy at any time. We encourage you to review the Privacy Policy regularly on our website. Continuing to use the Application, Websites, or Services, or continuing to communicate or engage with NTSpace after any revisions, updates, or amendments to the Privacy Policy, whether or not you have reviewed them, will constitute your acceptance and agreement to those revisions, updates, or amendments.

13. CONTACT

If you have any questions about this Policy, how we handle or process personal data, or any other inquiries, please contact us with your queries, feedback, and comments at info@ntspace.edu.vn