1. INTRODUCTION
1.1 Website https://ezcloud.vn/ is operated by ezCloud Global Technology Company Limited, its affiliates and related organizations (individually referred to as “ezCloud”, and collectively referred to as “We”, “Our” in this document). ezCloud is committed to respecting the privacy and personal issues of all Users on the ezCloud website (“Website”) (We collectively refer to the Website and the services We provide described on the Website as the “Services”). We recognize the importance of the personal data you have entrusted to Us and believe that it is Our responsibility to properly manage, protect and process your personal data. This Privacy Policy (the “Privacy Policy” or “Policy”) is intended to provide general information about how We will collect, use, disclose or otherwise process the personal data you have provided to Us, whether now or in the future; and how We will assist you before making any decisions regarding providing your personal data to Us. Please read the Privacy Policy carefully. If you have any questions regarding this information or Our privacy practices, please see the “Questions? Contact Us” section at the end of this Privacy Policy. 1.2 By using the Services, registering for an account with Us, visiting Our Website, or accessing the Services, you acknowledge and agree to the requirements, and/or policies, practices set forth in this Privacy Policy, and you consent to Us collecting, using, disclosing, and/or processing your personal data in the manner described herein. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR WEBSITE. If We change the Privacy Policy, We will post such changes or modifications on Our Website. We reserve the right to modify this Privacy Policy at any time.
2. WHAT INFORMATION DOES EZCLOUD COLLECT?
2.1 “Personal Data” is defined as data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data may include: Full name, ID number and contact information.
2.2 We will/may collect personal information about you:
(a) When you register and/or use our services or Website, or open an account with us;
(b) When you submit any form, including but not limited to application forms or other forms relating to any of our products and services, whether online or by other means of delivery;
(c) When you enter into any agreement or provide us with any documentation or information relating to your interactions with us, or when you use our products and services;
(d) When you interact with us, such as through telephone calls (which may be recorded), letters, faxes, face-to-face meetings, social media platforms and emails;
(e) When you use our electronic services, or interact with us through our applications, or use services on our Website. This includes through Cookies that we may deploy when you interact with our applications, Websites or Software;
(f) When you make transactions through our services;
(g) When you provide us with feedback or complaints;
(h) When you submit your personal data to us for any reason;
The above are just some of the common instances in which we collect your personal data, and are not intended to be exhaustive.
2.3 When you access, use or interact with our mobile application, Website or Software, we may collect certain information by automated or passive means using a variety of technologies, which may be downloaded to your device and may set/modify settings on your device. The information we collect may include your Internet protocol (IP) address, your computer/mobile device operating system and browser type, type of mobile device, the characteristics of your mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your device, the address of a referring website (if any), your visit history to our Website, Software and mobile applications. We may collect, use, disclose and/or process this information for the Purposes (defined below).
2.4 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. For most mobile devices, you can withdraw your permission to obtain your location information through your phone settings. If you have questions about how to disable location services on your mobile device, please contact your mobile phone service provider or the device manufacturer.
2.5 Personal Data collected includes, but is not limited to:
Full name
Email address
Telephone number
Work address
Position
Work location
Any other information about the User when the User logs in and uses Our services or Website, when the User uses Our services or Website, as well as information related to how the User uses Our services or Website
Aggregated data about the User’s activity history
3. ACCOUNT SETTING UP
Certain features of the Service require you to create a User account and submit personal data. When you register and create a new account, We ask you to provide Us with information such as your full name, email address, and the name of the Hotel where you work. We also ask for certain personal information such as your phone number, email address, hotel address, ID number, etc. After activating your account, you will choose a Username and password. Your Username and password will be used to securely access and maintain your account.
4. ACCESSING THE SITE
As with most Websites, your device may send to Our Website some personal information that you use to log in. This information typically includes, but is not limited to: your computer’s IP address, operating system, browser name/version, referring Web page, requested page, date/time, and sometimes a “Cookie” (which can be disabled using your browser preferences) to help the Site remember your last visit. If you are logged in, this information is associated with your personal account. This information is also included in anonymous statistics to allow Us to understand the browsing habits of Users.
5. COOKIES
5.1 We may use “Cookies” or other features to allow Us or third parties to collect or share information that helps Us improve the Site and the Services We provide, or helps Us provide new services and features. “Cookies” are identifiers We transfer to your computer or mobile device that enable Us to recognise your computer or device and tell Us how and when Our Services or Website are used or visited, by how many people and to track actions taken on Our Website. We may link cookie information to personal data. Cookies also collect information regarding what you have put in your shopping cart and which pages you have viewed. Cookies are also used to deliver content relevant to your interests and to track your use of the Website.
5.2 You may refuse the use of Cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of Our Website or Services.
6. COMMUNITY & SUPPORT
We provide customer support via email, SMS and other forms of interaction. In order to provide customer support, We will ask customers to provide an email address and mobile phone number. In addition, We do not request any other personal data in order to provide customer support. We only use the information received when customers request support, including email addresses, for customer support and We will not transfer or share this information with any other third parties.
7. USER SURVEY
At some point, We will request information from Users through surveys. Participation in surveys is completely voluntary, so you can choose whether or not to provide your information to Us. The information requested may include contact information (such as your email address), and personal information. Survey information will be used for survey purposes and to improve the use of the Service and will not be transferred to third parties.
8. HOW DO WE USE THE INFORMATION YOU PROVIDE?
8.1 We may collect, use, disclose and/or process your personal data for one or more of the following Purposes:
(a) To consider and/or process your request/transaction with Us;
(b) To manage, operate, provide and/or administer your use of and/or access to Our Services, Software or Website, as well as your User account and relationship with Us;
(c) To manage, operate and provide to you and facilitate the provision of Our Services, including remembering your requests;
(d) Improve your experience using the Services by providing a faster method for you to access your account and submit information to Us, allowing Us to contact you if necessary;
(e) To receive, process, negotiate or complete a transaction and/or to fulfill your requests for certain products and services and notify you of service issues and unusual account activity;
(f) To enforce Our Terms of Service or any applicable End User License Agreement;
(g) To protect your personal safety, rights, property or the safety of others;
(h) To identify or verify;
(i) To maintain and administer any software updates and/or other updates that may be required from time to time to ensure the smooth operation of Our Services;
(j) To process or conduct customer service, provide instructions to you, receive or respond to any requests made by (or purported to be made by) you;
(k) To contact you by telephone, text message and/or fax, email and/or postal mail, or other means to maintain your relationship with Our Services. You understand and acknowledge that when We contact you by postal mail, some of your personal information such as your full name, delivery address will be disclosed on the envelope.
(l) To conduct research, analysis and development of the Services (including data analysis, surveying, product and service development and/or development), to analyze User behavior for the Purpose of improving Our Services or products and/or to improve the User experience;
(m) For marketing purposes, we will send you information by various means of communication such as postal mail, email, location-based services, promotional information and materials relating to products and/or services (including products and/or services of third parties with whom ezCloud collaborates or works) that ezCloud (and/or its affiliates or related entities) is selling, marketing or promoting, whether such products or services exist now or are created in the future. We will not send you marketing or promotional information by phone, SMS/MMS or fax, unless it is not in breach of applicable laws or We have previously received your express consent; (n) For legal purposes or to comply with or respond to any law or governmental or regulatory request of any relevant authority, including, without limitation, to make disclosures required by law to which ezCloud or its affiliates or related companies are bound;
(o) To collect statistics and research for internal reporting in accordance with statutory and/or record-keeping requirements;
(p) To audit the Services or ezCloud’s business;
(q) To prevent or investigate any fraud, illegal activity, omission or wrongdoing, whether related to your use of our Services or any other matter arising from your relationship with us, whether or not there is any suspicion of such;
(r) To store, back up, restore (whether for troubleshooting or not) your personal data, whether within or outside Vietnam;
(s) To process or facilitate transactions to which ezCloud is a party or involves an affiliate or related entity as a party or involves ezCloud and/or one or more of ezCloud’s affiliates/related entities as parties and which may involve a third party organization.
(t) Any other Purposes which We notify you of at the time of requesting your consent.
(collectively, the “Purposes”);
8.2 Some of the Purposes for collecting, using, disclosing or processing personal data depend on the circumstances at the time of collection and may not appear in the list above. However, We will notify you of such Purposes at the time of obtaining your consent, unless the processing of personal data without the consent of the owner is required by law.
9. HOW DOES EZCLOUD PROTECT USER INFORMATION?
We implement a variety of security measures to ensure the safety of your personal data on our systems. User data is stored behind secured networks and is only accessible by a limited number of employees who have special access rights to the systems. We will retain personal data in accordance with applicable laws. However, we will destroy or anonymize your personal data as soon as it is reasonable to assume that (i) the Purpose for which the personal data was collected is no longer being served; and (ii) retention is no longer necessary for any legal or business purpose. If you stop using the Software or the Website, or your permission to use the Website and/or the Services is terminated, we may continue to store, use and/or disclose your personal data in accordance with this Privacy Policy and our obligations under the law. Subject to applicable law, we may securely process your personal data without prior notice to you.
10. DOES EZCLOUD DISCLOSE YOUR PERSONAL INFORMATION TO OUTSIDE PARTIES?
10.1 In the course of our business, we will/may need to disclose your personal data to third party service providers to us, our agents and/or our affiliates or related corporations, and/or other third parties, regardless of where those Websites are located, for one or more of the Purposes listed above. Such service providers, agents and/or affiliates or related companies and/or other third parties will be processing your personal data on our behalf or otherwise for one or more of the above Purposes. Such third parties include:
(a) Our subsidiaries, affiliates and related companies;
(b) Contractors, agents, service providers and other third parties that we use to support our business, including but not limited to those who provide administrative or other services such as postal companies, telecommunications companies, information technology companies and data centres;
(c) A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of ezCloud’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which your personal data is among the assets transferred; or to a counterparty in a business asset transaction that ezCloud or its affiliates or related corporations are involved in;
(d) Third parties to whom We disclose information for one or more of the Purposes and such third parties will in turn collect and process your personal data for one or more of the Purposes.
10.2 In addition to the above, this sharing of information may require sharing statistical and demographic information about our Users and their use of the Services with advertising and programming providers. This will not include anything that could be used to identify you specifically or to discover personal information about you.
10.3 For the avoidance of doubt, where data protection laws or other laws permit an organisation such as Us to collect, use or disclose your personal data without your consent, that permission continues to apply.
10.4 This Privacy Policy is not a promise that your personal data will never be disclosed, except as described in this Privacy Policy. For example, third parties may unlawfully intercept access to personal data transmitted to or contained on the Website, technology may malfunction or not function as intended, or someone may access, abuse or misuse information through no fault of Ours. We will always implement reasonable security measures to protect your personal data in accordance with applicable laws; however, there can be no guarantee of absolute security against unauthorized disclosure arising from malicious and sophisticated hacking by disgruntled parties through no fault of ours.
11. INFORMATION COLLECTED BY THIRD PARTIES
11.1 Our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses Cookies, text files placed on your computer, to help the Site analyze how Users use the Site. The information generated by the Cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operations and providing other services related to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
11.2 We, along with third parties, may from time to time provide downloadable applications through our Services. These applications may allow third parties to view your identity information, including your name, User ID, your computer’s IP address, or other information such as Cookies that you have installed or allowed a third party to install on your application/website. Products/services provided by third parties are not owned or controlled by ezCloud. We encourage you to carefully read the terms and other Policies provided by third parties on their Websites and other media.
12. SECURITY DISCLAIMER AND THIRD PARTY WEBSITES
12.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL AND/OR OTHER INFORMATION THAT YOU PROVIDE TO Third Party Websites. We implement a variety of security measures to maintain the safety of your personal data in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. When you access your personal data, we provide the use of a secure server. All personal data or information you provide is encrypted into our databases to be accessed only as stated above.
12.2 We will endeavor to provide you with products with added value, we may choose various third party websites to link to, and frame within the websites. We may also enter into co-branding and other relationships to provide e-commerce and other services and features that we create. Linked sites have separate and independent privacy policies and security arrangements. Even if the third party is affiliated with Us, We have no control over those linked sites, which have separate and independent privacy and data collection practices. Data collected by Our co-branded partners or third party websites (even if provided on or through Our Site) may not be received by Us.
12.3 We therefore have no responsibility or liability for the content, security arrangements and activities of linked sites. Linked sites are provided for your convenience only and you therefore access them at your own risk. However, We seek to protect the integrity of Our Site and the links placed upon them and We welcome any feedback about the linked sites (including if a particular link does not work).
13. ACCESSING OUR WEBSITE FROM OVERSEAS?
If you are accessing our Website or communicating with us from overseas, please note that your personal data and/or information may be transferred to, stored, processed in Singapore, where our servers, central database and facilities are located. The data protection and other laws of Singapore and other countries may differ from those of Vietnam. By using our Website or purchasing our products or services, you acknowledge that your personal data and/or information may be transferred to our facilities and to third parties with whom we share it as described in this Privacy Policy.
14. HOW CAN YOU OPT OUT, REQUEST ACCESS, OR CHANGE THE INFORMATION YOU HAVE PROVIDED TO US?
14.1 Opting Out and Withdrawing Consent
14.1.1 To modify your email subscription, please let Us know by emailing Our Customer Care at the address listed below. Please note that you will still receive email notifications related to the app itself.
14.1.2 You may withdraw your consent to the collection, use and/or disclosure of your personal data in our possession or control by sending an email to our Customer Care team at the email address listed in Section 15.
14.1.3 Once we have provided you with clear instructions for withdrawing your consent and have verified your identity, we will process your request for withdrawal of consent and will thereafter not collect, use and/or disclose your personal data in the manner set out in your request. If we are unable to verify your identity or understand your instructions, we will contact you to clarify your request.
14.1.4 However, withdrawing your consent may result in certain legal consequences arising from the withdrawal of consent. In this regard, depending on the extent of your withdrawal of consent for Us to process your personal data, it may mean that we will not be able to continue to provide the Services to you, We may need to terminate your existing relationship with you and/or the contract you have with Us and We will notify you.
14.2 Requesting access to and/or correction of personal data
14.2.1 If you have registered an account with Us, you may directly access and/or correct your personal data currently in Our possession or control via the Account Settings pages on the Software. If you have not registered an account with Us, you may request to access and/or correct your personal data currently in Our possession or control by submitting a written request to Us. We need to have enough information from you to identify you and the nature of your request so that we can deal with your request. Therefore, please submit your request in writing by emailing our data protection officer at the email address listed below in Section 15.
14.2.2 For a request to access personal data, once we have sufficient information from you to deal with the request, we will provide you with the relevant personal data within 30 days. Where we are unable to respond to you within 30 days, we will notify you of the earliest possible time within which we can provide you with the requested information. Please note that we may exempt certain types of personal data from your access request.
14.2.3 For a request to correct personal data, once We have sufficient information from you to process, We will:
(a) Correct your personal data within 30 days. Where We are unable to do so within 30 days, We will notify you of the earliest possible time We can do so.
(b) We will send the corrected personal data to any other organisation to which We have disclosed the personal data within 1 year before the date the correction is made, unless the other organisation does not need the personal data for any legal or business purpose.
14.2.4 Notwithstanding (b) above, if you request, We may only send the corrected personal data to specific organisations to which We have disclosed such personal data within 1 year prior to the date the correction was made.
14.2.5 We reserve the right to refuse to correct your personal data in accordance with the provisions set out in relevant laws, which require and/or permit an organisation to refuse to correct personal data in certain specified circumstances.
15. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
15.1 If you have any questions or concerns about our privacy practices or your dealings with the Services, please contact ezCloud at support@ezCloud.vn
15.2 If you have any complaints regarding the way we are handling your personal data or about how we are enforcing the law, we welcome you to contact us via support@ezCloud.vn or hotline 1900 6159
15.3 If you send a complaint request via letter or email, please include information about the complaint regarding the application of the law related to personal information security in the subject line of the email. This will help us to process your request promptly by forwarding it to the responsible department within our company for further processing. For example, you can add “Law Complaint” in the subject line of the email/letter.
We will endeavour to resolve your complaints or claims as soon as possible.
16. GOVERNING LAW
This Privacy Policy is governed by the laws of the Socialist Republic of Vietnam.
17. TERMS AND CONDITIONS
Please read the Terms of Service regarding the use, disclaimers and limitations of liability when using the Sites, Services and other related policies.
