2. The information we collect
We only collect Personal Data relevant to promotion and operation of the Service, the opening administration of Accounts and enforcement of Consumer Agreements. Such Personal Data is given directly by you and by people or companies authorized by you to act on your behalf, and it may also include information obtained from those third parties authorized by you to share such information with us, including:
(a) Information that you provide by filling in forms on the Service, posting User Content or requesting further services or reporting a problem;
(b) Name, addresses, date of birth, gender and contact details;
(c) Payment details (e.g. account number, sort code; payment card number, validity/expiry date, issue number and CVV number);
(d) Any other data or information that we or any of our suppliers must request from you in order to perform our service
(e) Information about your financial interests or financial position;
(f) Your contact details, including your e-mail address, home address and telephone numbers;
(g) Copies of passports or other identification evidence that you provide for anti-money laundering and anti-fraud purposes;
(h) Records of telephone calls and any correspondence between you and us;
(i) Records of any surveys that you may be asked to complete for research purposes, although you do not have to respond to them;
(k) Internet protocol address, timezone/region, browser type/language, operating system, internet service provider, system details/settings;
(l) Information about activities you undertake, such as the pages you visit, searches you make or marketing or links you click;
(m) Transaction Data: retailers used, items purchased, value of transactions;
(n) Information relating to any criminal proceedings in which you have been involved;
(o) Credit checks to assess creditworthiness of your Business.
We aim to keep your personal information up-to-date, so please advise us of any changes by updating your Account or e-mailing insert email address. You must notify us by emailing insert email address within thirty days if any of any change in your name, residential address, contact details, identification evidence given to us and any other details that we reasonably consider to be material to our dealings with you in relation to the Service.
3. Where we store your Personal Data
Our main data storage facilities are located within Viet Nam. We store Personal Data outside Viet Nam, in compliance with the legislation of certain jurisdictions that require the personal data of its citizens to be stored within its borders, this is purely for purposes of backup and is a technical necessity.
Once we have received your Personal Data, we will use procedures and security features to try to prevent unauthorized access, unlawful processing, accidental loss or destruction of, or damage to it, provided that you comply with the provisions of the Consumer Agreement relating to the security of your Account Access Codes. However, the transmission of information via the Internet is not completely secure and, while we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our Service and any transmission is at your own risk.
4. Use of Personal Information
We act as data controller when processing and storing your Personal Data.
We may use information held about you in one or more of the following ways:
(a) To ensure that content on the Service is presented in the most effective manner for you and for your computer or other devices for which we support access;
(b) To provide you with information, products or services that you request or which we decide may interest you, where you have consented to be contacted for such purposes;
(c) For statistical analysis;
(d) To develop and improve the Service;
(e) To update our records;
(f) To identify which elements of the Service or other products might interest you;
(g) To assess creditworthiness in accordance with the provisions of the applicable Customer Agreement;
(h) To identify, prevent, detect or tackle fraud, money laundering and other crime;
(i) To carry out checks required by applicable regulation or regulatory guidance;
(j) To keep you informed about the Service and/or Transactions;
(k) To carry out our obligations arising from and exercise our rights under, any agreements between you and either of us or other users of the Service;
(l) To allow you to participate in interactive features of the Service, when you choose to do so.
(m) To give you any notices under your Customer Agreement.
5. Disclosure of your information
We will keep your Personal Data confidential and only disclose it to others for the purposes explained when you applied, and:
(a) In the event that we sell or buy any business or assets, in which case it may disclose your Personal Data to the prospective seller or buyer of such business or assets;
(b) If substantially all of our assets are acquired by a third party, in which case Personal Data held by us about our customers will be one of the transferred assets;
(c) If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply any agreements to which you are a party; or to protect our rights, property, or safety, or that of our customers, or others (which includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction);
(d) If you request us, or give your permission for us to do so;
(e) To a credit reference agency to check your identity and to prevent fraud, (it will also keep a record of your request and use it whenever anyone applies to be authenticated in your name);
(f) To tell credit reference agencies that you have an account and how you run that account;
(g) To our suppliers, agents and subcontractors to use for the purpose of operating the Service, under an obligation to take appropriate technical and organizational security measures against the unauthorized or unlawful processing of Personal Data and against the accidental loss or destruction of, or damage to, such Personal Data;
(h) To investigate, prevent or detect fraud or carry out checks against money laundering;
(i) To organizations providing a centralized application matching service which they collect from and about credit applications, for the purpose of preventing and detecting fraud;
(j) For audit purposes and to meet obligations to any relevant regulatory authority or taxing authority.
We will also check your details with a fraud prevention agency/agencies and if you give false or inaccurate information and we identify fraud, this will be recorded and we and other organizations, including law enforcement agencies and debt collection agencies, may access, use and search these records to:
(a) help make decisions about credit and credit related services, for you and members of your household;
(b) help make decisions on motor, household, credit, life and other insurance proposals and insurance claims, for you and members of your household;
(c) trace debtors, recover debt, prevent fraud, and to manage your accounts or insurance policies;
(d) prevent fraud and money laundering, for example, when:
- Checking details on applications for credit and credit related or other facilities;
- Managing credit and credit related accounts or facilities;
- Checking details on proposals and claims for all types of insurance; and
- Checking details of job applicants and employees.
Please contact us at insert email address if you want to receive details of the relevant fraud prevention agencies.
6. Your rights
You have the right to ask us not to process your Personal Data for marketing purposes. We will inform you if we intend to use or disclose your Personal Data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms used to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
The Service may, from time to time, contain links to and from the websites of other businesses, including networks, advertisers and affiliates. If you follow a link to any of these websites, please note that those third parties have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any Personal Data directly via those websites or to those third parties.
Under the Data Protection Act 1998, you have a right to access your Personal Data that we hold. Any access request may be subject to a fee to meet our costs in providing you with those details of the Personal Data that we hold.