This Personal Data Protection Policy (“Policy”) is implemented by Ajinomoto Vietnam Co., Ltd (“the Company”) and describes the activities of Ajinomoto Vietnam Co., Ltd with respect to the processing of Personal Data (“PD”) of the Customer/Individual (herein collectively referred to as “the Honorable Visitor”). 

1.The general principle 
1.1.This Policy governs the manner in which the Company collects, processes, uses, stores, deletes and shares PD of the Honorable Visitor in accordance with the law (“Processing”) and ensures the security of the Honorable Visitor’s information when the Honorable Visitor accesses information and uses products and services (hereinafter referred to as “Products/Services”) on the websites of the Company (hereinafter referred to as “Website”) and websites linked to the Company's Website. The Company encourages the Honorable Visitor to read this Policy carefully and regularly check the Website to stay informed of any changes the Company may make from time to time.

1.2.PD that the Company processes is information in the form of symbols, letters, numbers, images, sounds or similar forms in the electronic environment associated with a specific person or helping to identify a specific person.

1.3. All PD arising from Products/Services will be ensured by the Company as follows: 
a.Processing and ensuring safety according to the provisions of this Policy and relevant laws;
b.Processing for the purposes as stipulated in the Article 5 below; 
c.PD will be collected appropriately and limited to the purpose of Processing;
d.Do not purchase or sell in any form; 
e.Allowing the Honorable Visitor to access, supplement information in accordance with the purpose for Processing; 
f.Appling protection and security measures during the time of Processing, including protection against violations of regulations on data protection and prevention of loss, destruction or damage due to incidents.
g.Storing for a period of time consistent with the purpose of Processing, unless otherwise required by law. 

1.4.The Company processes and ensures the safety of PD as the Data Controller and Processing in accordance with this Policy.

1.5.By accessing, creating an account at the Website, agreeing to answer questions at the Website and clicking "I agree" to this Policy and/or any other form, the Honorable Visitor agrees to allow the Company to process PD specified in this Policy to receive Products/Services from the Company.

1.6.If the Honorable Visitor does not agree to allow the Company to process PD as described in this Policy, the Honorable Visitor may not be able to access or use the Products/Services from the Company's Website.

1.7.    The Company has the right to amend and supplement this Policy at any time and depending on the purpose, scope, and content of such amendment. Notice of any amendment will be posted on the Company’s Website and/or such other means of communication as the Company deems appropriate. The Company recommends that the Honorable Visitor needs to regularly review this Policy for changes and to stay informed about how the Company protects the Honorable Visitor’s PD. The Company may notify the Honorable Visitor and obtain the Honorable Visitor’s consent in the form stipulated at Clause 1.5 of Article 1 of the Policy or depending on the provisions of law on the protection of PD from time to time. Your continued use of the Website, application or device is deemed to be your continued acceptance of this Policy and related amendments and supplements.

1.8.The time to process PD begins from the time the Honorable Visitor provides information on the Website and accesses the Website and ends when the purpose of collecting PD has been met or is no longer needed.

1.9.The Honorable Visitor has the following rights: the Honorable Visitor can view, update, and delete certain DP and your interactions with the Website. If the Honorable Visitor is unable to access or update your information yourself, the Honorable Visitor may contact the Company for assistance. In addition, the Honorable Visitor can request the Company to exercise your other rights according to the law such as: right to withdraw consent, right to delete data, right to limit data Processing, right to provide data, right to object to data Processing by contacting the Company through the support channels in Article 10 below. The Honorable Visitor should note that in the event the Honorable Visitor withdraws your consent to allow the Company and its related parties for Processing PD, your consent and the Processing of PD by the Company and its related parties before this date is appropriate according to current legal regulations.

1.10.“Cookie” is a small file created by a web browser and placed on the Honorable Visitor’s device when the Honorable Visitor accesses a Website. Cookies make the Honorable Visitor’s online experience easier by saving information about the Honorable Visitor’s device and browser to limit the need for the Honorable Visitor to log in multiple times, and in some cases, it can save the Honorable Visitor’s preferences and electronic browsing habits to optimize the provision of information that interests the Honorable Visitor.
The Honorable Visitor can use your browser settings to edit, delete or block Cookies on the Honorable Visitor’s device. However, this may affect the Honorable Visitor’s experience when accessing the Company's Website, the Honorable Visitor may not be able to take full advantage of all the features on the Company's Website.

2.Collecting Personal Data 
2.1.The Company only collects the Honorable Visitor’s PD that is appropriate and necessary for the purposes during a period of providing Products/Services to the Honorable Visitor.

2.2.The Company collects the Honorable Visitor’s PD in the following manners:
a.PD was provided by the Honorable Visitor to the Company related to the Products/Services:

• From the Company's Website and websites linked to the Company's Website: The Company may collect PD when the Honorable Visitor accesses information and uses Products/Services on the Company's Websites and other websites linked to the Company's Website.

• From exchanges and communications with the Honorable Visitor: The Company may collect PD when the Honorable Visitor contact the Company (in person, by mail, phone, online, electronic communication or any other means), including Honorable Visitor surveys, Honorable Visitor care emails conducted by the Company, receiving comments and complaints from the Honorable Visitor.

• The Honorable Visitor hereby understands and agrees that calls, messages and/or other forms of contact from and/or to the Company may be stored in a form including but not limited to recording sound and/or video, automatically or proactively, to support request resolution, update information systems, improve service quality and other lawful purposes.

• The Honorable Visitor is responsibles for ensuring the provided information that is complete, accurate and always updated to ensure the Honorable Visitor’s rights according to the regulations of using Products/Services. The Company is not responsible in case The Honorable Visitor provides an inaccurate or incomplete PD in accordance with the regulations of using Products/Services and relevant laws.

• In case the Honorable Visitor provides information of the third party to the Company, the Honorable Visitor represents and warrants that the Honorable Visitor has clearly informed the third party of the contents of this Policy and has fully obtained that third party's consent and approval for the Honorable Visitor’s provision of information to the Company and for the Company's use of that information in the manner and provisions of this Policy

• The Honorable Visitor warrants and undertakes that the Honorable Visitor provides information to the Company will not include any of the following categories of information: national secrets, business secrets and any other information that the Honorable Visitor is not permitted to provide it under the provisions of law or confidentiality agreement.

b.The legality of PD that the Company obtains from other sources: The Company may collect the Honorable Visitor’s PD from various sources, including but not limited to: from the Company's partners, referral programs, when the Honorable Visitor provides PD in surveys, investigations, promotions or similar forms and publicly available sources. Where the Company collects PD from other sources, the Company ensures that such PD is transferred to the Company in accordance with applicable law.
c.Collecting and using of Cookies: When the Honorable Visitor accesss the Company's Website and allows the use of Cookies, one or several Cookies may be created and saved on the Honorable Visitor’s device. Cookies can transmit PD and the use of Products/Services to the Company or partners are designated by the Company to enhance the Honorable Visitor’s experience while using the Products/Services, including but not limit the Honorable Visitor’s access to the Website faster and more conveniently by not wasting time logging in multiple times, as well as selecting and providing information that the Honorable Visitor is often interested in.

3.Processing Personal Data of the Company 
The Company will process the Honorable Visitor’s basic PD according to the provisions of current law that the Honorable Visitor provides related to the Products/Services, include some of the following information: full name, contact address, phone number, email and activities on the Company's Website and websites linked to the Company's Website.

4.The rights of the Honorable Visitor related to Processing Personal Data of the Company 
4.1.The Honorable Visitor can choose not to provide certain information, but then the Honorable Visitor may not be able to take advantage of certain Products/Services. Please follow the Company's instructions from time to time:
a.Account information: If the Honorable Visitor wants to supplement, update or delete information related to the Honorable Visitor’s account, please follow the Company's instructions from time to time.
b.Communications: If the Honorable Visitor does not want to receive promotional messages from the Company, please unsubscribe or adjust the Honorable Visitor’s communication preferences according to the Company's instructions from time to time. 

4.2.Data deletion will not apply upon request of the data subject in the following cases:
a.The law does not allow data deletion;
b.PD is processed by competent authorities in order for serving the activities of state agencies in accordance with the law;
c.PD was published in accordance with the law;
d.PD is processed to serve legal requirements, scientific research, and statistics in accordance with the law;
e.PD is used to deal with emergency situations that threaten the life, health or safety of data subjects or other individuals.

4.3.Within 72 (Seventy-two) hours after receiving request of the Honorable Visitor, or another period prescribed by the relevant laws, all PDs were stored in the Company’s database and the Company had the right to use and easily searchable information shall be updated, corrected, changed or deleted entirely within the scope and ability of the Company and in accordance with the law.

4.4.In addition, the Honorable Visitor has other rights including: Complaining, denouncing, suing, requesting for compensation for damages and self-defense right in accordance with the law when detecting that the Company violates obligations relating to PD Processing and causes damage to the Honorable Visitor’s legitimate rights and interests. 

5.Purposes of Processing the Honorable Visitor’s PD
By checking the “Agree” box, the Honorable Visitor agrees to the Company Processing PD for the following purposes:
5.1.Providing Products/ Services; Implementing promotional and support programs of the Company.

5.2.Using and analyzing the Honorable Visitor’s information to develop, provide and continuously improve the quality of services in order to meet the requirements of the Honorable Visitor.

5.3.Sending the Honorable Visitor information of Products/ Services that is not only based on your demands and interests but also in accordance with applicable laws on direct marketing.

5.4.Online advertising or advertising based on the Honorable Visitor’s demands and interests.

5.5.Displaying the content of Website, apps, devices and other customizations that the Honorable Visitor may choose.

5.6.Managing content, promotions, surveys or other features of the Websites, apps, devices or survey platforms.

5.7.Managing the Honorable Visitor’s account and features of Websites, apps or devices.

5.8.Verifying identity and protecting PD of the Honorable Visitor.

5.9.Notifying the Honorable Visitor on changes to the Products/Services or upon changes, technical notices, security alerts, support, administration, or updates to the Company’s Regulations/ Policies. 

5.10.Answering comments, questions and providing Products/ Services to the Honorable Visitor.

5.11.Other purposes according to the relevant agreement when the Honorable Visitor uses the Products/Services, Website of the Company and other third parties.

6.Other Parties Processing with Personal Data
The Company and its Data Processors shall have the right for Processing PD for the purposes stated in Article 5.

7.Storing and Protecting the Honorable Visitor’s PD
7.1.When Processing the Honorable Visitor's PD, the Company will make maximum efforts within the allowable scope to store and protect the aforementioned data on the server system. In addition, PD is secured by firewall systems, access control measures and data encryption. The Company has appropriate technical and security measures to prevent to the maximum possible extent the illegal use and access to the Honorable Visitor’s PD. The Company also coordinates with security experts to update the latest information on cyber security to protect the Honorable Visitor’s PD. In case the Company's system is attacked and there is a risk of harming the security and confidentiality of the above-mentioned data, the Company will comply with its obligations under the law to apply remedial measures and notify the Honorable Visitor as well as the competent authority.

7.2.The Honorable Visitor does not use any tools, programs or other measures affecting the work of system or change data structure of any Product/ Service, or any other act to spread, encourage activities interfering, sabotaging or infiltrating the Company's system data, as well as other acts that violate Vietnamese law. In case the Company detects that the Honorable Visitor has committed a violation, the Company has the right to transfer information of the above-mentioned act to competent authority for handling in accordance with the law. 

7.3.The Honorable Visitor responsibles for protecting the account information and not providing any information related to this account, password or authentication methods (e.g. OTP) to access on websites, applications, software and other tools (if any).

7.4.The Company is not responsible for problems arising when the Honorable Visitor uses Products/Services from tools and interfaces other than the Website allowed to be used within the framework. On the other hand, the Products/Services may contain links to and from the services of partner networks, advertising companies. Please note that each party will have its own privacy policy and the storage, confidentiality and use of the information provided to these parties is outside the scope of the Company's management. Therefore, the Company shall not assume any responsibility or liability for the storage, confidentiality and use of this information. Please check their privacy policies, security policies or similar policies before submitting any personal data to them.

7.5.The Company stores the Honorable Visitor’s PD to ensure the Honorable Visitor’s ability to use continuously the Products/Services and store them for as long as necessary to fulfill this purpose or cases required by law or to perform other tasks as notified to the Honorable Visitor in advance. The amount of time that the Company stores the PD depends on its purpose. When the Honorable Visitor’s PD is no longer required for the provision, use of the Products/Services or the purpose or the Company no longer has a business purpose or proper grounds under law to retain your PD, the Company will dispose the PD in accordance with applicable laws regarding PD storage.

7.6.The Honorable Visitor’s PD can be transferred outside Vietnam through storage on servers leased by the Company in overseas data centers. In this case, the Company ensures that the transferred information is in accordance with this Policy and relevant laws. 

7.1.The overseas PD transfer period starts from the time the Honorable Visitor provides information on the Website located at the server leased by the Company at the overseas data center and ends when the Company ends the server lease at the overseas data center or when the purpose of collecting PD has been met or is no longer necessary.

8.Third-party services
The Company has no control over the content or links appearing on the third-party websites or services and the Company is not responsible for the practices used by the above-mentioned websites or services linked to or from any Website, which app, or device. These websites and services may be subject to third parties' privacy policies and terms of use.

9.Share of PD 
The Company may share the Honorable Visitor’s PD for the purpose of this Policy, whereby, PD is shared among entities and in the following cases:
9.1.Sharing the Honorable Visitor’s PD with suppliers, consultants, marketing partners, research companies and other service providers or business partners. This includes: payment Processing and support departments; server service providers, information technology services, cloud storage providers; advertising partners and advertising platform providers; data analytics providers; research partners, including those who conduct surveys or research projects in partnership with or on behalf of the Company in connection with the Company's Products/Services. 

9.2.Sharing the Honorable Visitor’s PD for legal purposes, legal requirements, legal process, protection, or security in accordance with relevant laws, as required by competent authorities.

9.3.Sharing the Honorable Visitor’s PD in case of emergency. This includes protecting the safety of our employees and agents or any of our stakeholders.

10.Contact information
Our contact information is detailed as follows:
AJINOMOTO VIETNAM CO., LTD
Phone number: 028 3930 8784;                 Email: tvkh@ajinomoto.com.vn
Address: Bien Hoa I Industrial Park, An Binh Ward, Bien Hoa City, Dong Nai Province, Vietnam.