Nam Long Technology Investment Group (NLT Group)

Updated on 15 December 2025

Nam Long Technology Investment Group (hereinafter referred to as “NLT Group”) publishes this Privacy Policy to demonstrate its commitment to protecting customers’ personal information and to comply with applicable laws and regulations relating to data safety and security when Users access and use websites/applications/products/services provided by NLT Group.

When individuals, organizations, or enterprises (hereinafter collectively referred to as “Users”) provide information to establish a relationship, create an account, or use products or services of NLT Group, Users are deemed to have read, understood, and agreed to this Policy.

This Policy may be amended or supplemented from time to time. Users are advised to regularly check the official website/application of NLT Group for the latest version. Continued access to or use of the services after the update date shall be deemed acceptance of the updated Policy.

Terms used in this Policy shall be consistently understood and applied in accordance with the relevant agreements/terms of service applicable to each product or service used by the User.

II. Subjects and scope of application

1. Subjects of application

This Policy applies to individuals, organizations, and enterprises that use or are related to the use of products/services provided by NLT Group.

2. Scope of application

This Policy governs NLT Group’s processing of personal data (including one or more activities such as: collection, recording, analysis, verification, storage, modification, access, retrieval, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction, or other related activities) when Users register for and use products/services of NLT Group.

Personal data means information in the form of symbols, letters, numbers, images, sounds, or similar forms in an electronic environment that is associated with or helps identify a specific individual.

Sensitive personal data (depending on the circumstances) may include: identification information as prescribed by law; account information; information relating to money, assets, and transactions; information about guarantor organizations/individuals (if any); and location data determined through positioning services.

This Policy also applies to online services, means, tools, and applications related to the provision of products/services by NLT Group, regardless of the method used by Users to access them.

III. Data and information collected by NLT Group

NLT Group collects data necessary to provide, operate, and ensure legal compliance for its products/services. Some information is not mandatory; however, if Users do not provide such information, their experience or ability to use certain features may be affected.

Depending on the type of service, NLT Group may collect the following categories of data:

1. Information provided by users

Information provided when establishing a service/cooperation relationship, creating an account, using features, or registering for new products/services, including but not limited to:

  • Full name

  • Date of birth

  • Gender

  • Phone number

  • Other information arising from User provision or system collection, access, or storage as permitted in specific cases

In addition, NLT Group may record:

  • Updates, modifications, supplements, or replacements made by Users

  • Users’ activity history on applications/websites provided by NLT Group

  • Related activities on other platforms within the service ecosystem provided or co-provided by NLT Group (if any)

2. Information collected from other lawful sources

NLT Group may collect information from various lawful sources, such as:

  • Agreements/contracts between NLT Group and Users

  • Information channels of competent authorities

  • Communications via contact channels between NLT Group and Users, including interactions with support staff

  • Information provided by Users through feedback, surveys, discussions, complaint or dispute resolution, or other lawful interactions

To improve service quality, NLT Group may monitor or record calls with Users in compliance with applicable laws.

3. Automatically collected information

When Users access websites/applications/products/services, the system may automatically record information such as:

  • IP address

  • Data regarding websites/applications accessed

  • Location data (if permitted by Users and if location features are used)

  • Device identification ID and device type

  • Mobile/network device information and basic technical specifications

  • Display statistics and technical data for operation, security, and analysis

NLT Group and/or its partners and service providers may use cookies and similar tools (“Cookies”) to:

  • Identify Users and customize experiences

  • Measure program effectiveness and conduct analysis

  • Reduce risks, prevent fraud, and enhance safety and reliability

  • Personalize content and product/service recommendations (if any)

Users may set permissions to allow or disallow the collection of certain information on their devices depending on device structure and application features.

4. Information generated by NLT Group’s systems or from public sources

This may include:

  • Identification codes, AppIDs, and technical data enabling system recognition of Users

  • Information publicly disclosed by Users on NLT Group fanpages/social media channels or NLT Group websites/applications

  • Other information necessary to fulfill legal obligations

IV. Information relating to children and minors

NLT Group’s products/services are not directed at individuals under 13 years of age. In some cases, the age limit may be higher depending on regional regulations; Users should refer to applicable local supplemental terms (if any).

Where NLT Group relies on consent as a legal basis and the law requires parental/guardian consent, such consent may be requested prior to collection and use of information.

Where Users are children (unless otherwise provided by law), Users agree that:

  • NLT Group may collect consent from Users and their parents or legal guardians in accordance with regulations

  • NLT Group will cease processing and delete/destroy personal data in the following cases:
    (i) the processing purpose under the consent has been fulfilled;
    (ii) consent is withdrawn by parents or legal guardians;
    (iii) upon request by competent authorities where processing affects Users’ rights and interests

V. Purposes and methods of information use

NLT Group processes Users’ personal data for the following purposes:

1. Service provision and operation

  • Providing services and features to Users

  • Maintaining, operating, and improving products/services

  • Remembering information so Users do not need to re-enter it on subsequent visits

  • Contacting Users/partners regarding accounts, services, or cooperation (via calls, SMS, email, written documents, or other appropriate means)

  • Connecting Users’ accounts with third-party platforms (if applicable and based on User consent)

2. Verification, risk prevention and safety protection

  • Verifying accuracy, authenticity, and completeness of information

  • Assessing and classifying risks in accordance with Vietnamese law

  • Authenticating access rights during account creation and usage

  • Detecting and preventing fraud, infringement, abuse, or misuse of information

3. Customer support

  • Receiving and handling inquiries

  • Supporting verification, complaints, monitoring, and service quality improvement

4. Legal compliance and requests from authorities

  • Performing legal obligations

  • Responding to lawful requests from state authorities

5. Research, development and quality enhancement

  • Research and development to improve service quality

  • Performance measurement, technical system improvement, enhanced security and integrity

6. Promotional and marketing information (if any)

NLT Group may use data to introduce products/services, promotions, surveys, events, news, and related content of NLT Group and/or cooperating partners. Marketing may be conducted online or offline. Content and frequency will be announced for each program. When Users engage with promotional content, Users agree to NLT Group processing information in accordance with this Policy within the scope necessary for the program.

7. Investigation and dispute resolution

NLT Group may use information to investigate or resolve complaints, disputes related to service use, or other activities permitted by law.

VI. How NLT Group shares users’ information

NLT Group may share information in the following cases:

1. With service providers

Sharing with providers to operate services, monitor/analyze usage, and support Users within necessary scope.

2. With affiliates and subsidiaries

Sharing with subsidiaries, joint venture partners, or entities controlled or jointly controlled by NLT Group, subject to compliance with this Policy.

3. With business partners

Sharing to provide certain products/services or specific promotional programs within an appropriate scope.

4. Business transfer or restructuring

Information may be shared/transferred during negotiations or implementation of mergers, asset sales, financing, or acquisition of all or part of business operations in accordance with regulations.

5. Public areas shared by users

Information publicly posted or interacted with by Users may be viewed and widely distributed by others.

6. With user consent

NLT Group may disclose information for other purposes with valid User consent.

7. Legal reasons

NLT Group may provide information to law enforcement/state authorities/related organizations when:

  • Required by law; or

  • Reasonably necessary to comply with legal obligations, enforce terms/policies, investigate violations, detect/prevent fraud, security or technical incidents, or protect rights, property, or safety of NLT Group, Users, third parties, or the community.

VII. Data storage location and retention period

Users’ information may be stored on servers located outside the country of residence, such as Vietnam, Singapore, Malaysia, or the United States, to ensure continuous global operation.

NLT Group retains personal data only for as long as necessary to fulfill the purposes stated in this Policy and/or comply with legal obligations, resolve disputes, and enforce agreements and policies.

Data used for internal analysis is generally stored for shorter periods unless longer retention is required for enhanced security, feature improvement, or legal requirements.

VIII. Users’ rights and choices

Users may be provided with rights under applicable law, including (as applicable): rights to access, update/edit, delete data, restrict processing, object to processing, be informed of data processing, lodge complaints, initiate lawsuits, and other rights as prescribed.

Users may:

  • Log in to access and edit most profile information on applications/products/services (if available)

  • Delete history and provided data as applicable

  • Delete accounts in the Settings section (if supported)

Cookie management

Users may refuse/disable Cookies by adjusting browser or device settings. Due to differences between browsers and mobile applications, different steps may be required. Note: refusal or deletion of Cookies may result in certain features not functioning fully.

IX. Information security and disclaimer

NLT Group applies reasonable measures to protect personal data, including (where applicable) technical measures such as encryption. However, data transmission over the Internet cannot be guaranteed to be absolutely secure; Users bear the risks associated with transmitting information online.

NLT Group maintains technical and organizational measures appropriate to risk levels and will adjust and upgrade them over time to enhance system security.

Links to third-party websites/services

NLT Group platforms/services may contain links to third-party websites/services not operated by NLT Group. When accessing such links, Users are subject to the third parties’ privacy policies. NLT Group does not control and is not responsible for third-party content, privacy practices, or operations. Users should review relevant privacy policies before providing information.

X. Updates to the privacy policy

NLT Group may update this Policy from time to time. Upon updates, the “Updated on” date will be revised and the new Policy will be published on official channels or notified as required by law. If Users do not agree with the updated Policy, they must cease accessing or using the platform/services.

XI. Contact

For questions, comments, complaints, or requests related to this Policy, please contact: kinhdoanh@nlt-group.com

NLT Group will endeavor to respond as soon as possible. This provision does not affect Users’ rights to lodge complaints with competent data protection authorities (if applicable).

XII. Supplemental terms by legal jurisdiction

In case of conflict between “Supplemental Terms by Legal Jurisdiction” and the remaining content of this Policy, the applicable supplemental terms for the User’s jurisdiction shall prevail.

1. Methods of personal data processing

NLT Group may process personal data manually or automatically.

2. Rights and obligations of data subjects

Except for statutory exceptions, Users may have rights including:

  • Right to be informed

  • Right to consent and withdraw consent

  • Right of access

  • Right to data deletion

  • Right to restrict processing

  • Right to data provision

  • Right to object to processing

  • Right to complain, report, or initiate legal action

  • Right to claim compensation

  • Right to self-protection

Users may exercise these rights by contacting NLT Group as stated above, and NLT Group will respond accordingly, regardless of data storage location.

Users’ legal obligations include:

  • Protecting their own personal data

  • Requesting relevant organizations/individuals to protect personal data

  • Respecting and protecting others’ personal data

  • Providing complete and accurate personal data when consenting to processing

  • Other obligations under applicable law

3. Age and parental/guardian consent

If Users are under 16 years old or under guardianship:

  • Users must obtain consent from parents or legal guardians

  • Parents/legal guardians are responsible for Users’ access/use of services, compliance with this Policy, and ensuring compliance with child protection laws

If valid consent is not obtained or account creation is not permitted, Users must cease accessing/using products/applications/services until reaching at least 16 years of age.