Updated on October 16, 2023

Nam Long Technology Investment Group (hereinafter referred to as “NLT Group”) has developed and published this Privacy Policy to demonstrate our commitment and responsibility in protecting customers’ personal information. We ensure compliance with legal regulations on information security and confidentiality when customers access or use services provided by NLT Group.

When an organization, individual, or business (hereinafter collectively referred to as the “User”) provides information to establish a relationship, create an account, or use the products and services offered by NLT Group, NLT Group understands that you have agreed to and accepted this Privacy Policy.
This Privacy Policy is publicly available at: https://nlt-group.com/

This Privacy Policy may be amended, supplemented, or updated from time to time. Users are encouraged to regularly access and review the policy to stay informed of the latest changes. NLT Group reserves the right to modify any terms of this Policy at any time by publishing updates on its official website and/or displaying them on other official applications of NLT Group.

The terms used in this Privacy Policy refer to the agreements and service policies applicable to each specific product or service the User engages with.

By using the products and services of NLT Group, or by accessing and utilizing the websites, applications, products, or services provided by NLT Group, the User acknowledges and agrees to the practices, requirements, and/or policies described in this Privacy Policy. Accordingly, the User consents to NLT Group’s collection, use, and/or processing of their personal data as outlined in this Privacy Policy.

Scope and Applicability

Target Audience

Users include individuals, organizations, and businesses.

Scope of Application: 

  • The personal data processing activities of NLT Group (including one or more operations performed on personal data such as: collection, recording, analysis, verification, storage, modification, disclosure, combination, access, retrieval, revocation, encryption, decryption, duplication, sharing, transmission, provision, transfer, deletion, destruction, or other related activities) are carried out when the User registers for or uses the products and services provided by NLT Group.
  • Personal data refers to information about the User and all other information related to the User, presented in the form of symbols, letters, numbers, images, audio, or other similar formats in an electronic environment, which is associated with or can be used to identify a specific individual.
    Personal data includes basic personal data and sensitive personal data.
  • Data related to the User that qualifies as sensitive personal data includes: customer identification information as prescribed by law, account information, financial information, asset-related information, transaction details, information regarding organizations or individuals acting as guarantors for the customer (if any), and location data of the individual as determined through geolocation services.
  • Online services, platforms, tools, applications, and any other means related to the provision of products and services by NLT Group, regardless of the method used by the User to access or utilize them.

Data and Information Collected by NLT Group

NLT Group collects necessary user data and information to ensure the provision and operation of its products and services in compliance with applicable laws and regulations. Certain types of information are optional; however, failure to provide such information may affect the quality and overall user experience. Depending on the type of service you use, NLT Group may collect the following categories of personal data related to the User:

1. Information Provided by the User:

Information provided by the User when establishing a service relationship, entering into cooperation, creating a service account on applications owned by NLT Group, or when using a new feature or product offered by NLT Group. Specifically:

  • Full name;
  • Date of birth;
  • Gender;
  • Information and image of identity documents (ID card, Citizen ID, passport, including date and place of issue);
  • Phone number;
  • Facial photo of the User taken via device.
  • And other information (if any) that may arise as provided by you or permitted to be collected, accessed, and stored when the User uses any service, feature, or product deployed by NLT Group in specific cases.

Updated, modified, supplemented, or replaced information;

Information regarding User activities, including but not limited to::

  • History of information and activities performed by the User on applications provided by NLT Group.
  • Other activities carried out in collaboration between NLT Group and its partners on applications/websites provided by NLT Group.

2. Other types of information: 

  • Information and data regarding the User’s use of service features (if any);
  • Information provided by the User upon request from NLT Group or initiated by the User.

The collection of information is conducted from various sources, such as: through agreements/contracts entered into with the User; through information channels of competent authorities; through communication channels between NLT Group and the User; through User interactions with NLT Group staff; and even through other accounts that NLT Group has grounds to confirm are related to the User; feedback from the User via surveys; information during the User’s participation in discussions, dispute resolutions, or other relevant information provided in relation to the use of NLT Group’s services; 

In addition, for the purpose of improving and enhancing service quality, NLT Group may monitor or record conversations with the User or any individual acting on behalf of the User, in accordance with applicable laws.

Automatically Collected Information: 

  • Information sent to NLT Group from the computer, phone, or other devices the User uses to download or access services, such as: data on websites and applications accessed by the User, IP address, User’s location, device identification ID, device type, computer or mobile device information, network device information, statistics on website/application access and display, and other basic data;
  • When the User accesses NLT Group’s products or services, or accesses third-party websites or applications that have partnered with NLT Group to provide online services, NLT Group and its business partners or service providers may use cookies and similar tracking tools (collectively referred to as “Cookies”) to recognize the User as a returning customer and to personalize the User’s online experience, the services the User uses, as well as content, advertisements, and other online product promotions; to measure the effectiveness of promotional programs and conduct analytics; and to minimize risks, prevent potential fraud, and enhance trust and safety in NLT Group’s services;
  • When the User accesses or uses the services via a device, depending on the structure, features, and design of each type of device and provider, the User may configure or select which functionalities allow NLT Group’s products and services to access or use certain information, either partially or entirely, according to the User’s preferences.

Information Generated by NLT Group’s Systems or Support Channels: 

  • Information recorded by the system such as Identification Codes, AppID, and any other data generated by NLT Group’s system to identify you when accessing or using NLT Group’s products and services.
  • Information provided by the User on publicly available communication platforms such as NLT Group’s official Facebook fanpage, Zalo, website, or NLT Group’s applications.
  • Other information required for the purpose of fulfilling legal obligations in accordance with applicable laws.

3. Information Related to Children and Adolescents

NLT Group’s services/products are not intended for individuals under the age of 13. In certain jurisdictions, this age threshold may be higher due to local regulatory requirements. Please refer to your local supplementary terms for more information.

If NLT Group relies on consent as the legal basis for processing your information, and your country requires parental consent, NLT Group may request such parental consent before collecting and using that information. This means that, in the event the User is a child, unless otherwise provided by applicable laws, you agree that:

  • NLT Group reserves the right to obtain the consent of the User as well as the consent of the User’s parent or legal guardian, as required by applicable regulations.
  • NLT Group will cease the processing of the User’s personal data and irreversibly delete or destroy such data in the following cases: (i) NLT Group has fulfilled the purpose of data processing as consented by the User; (ii) The User’s parent or legal guardian withdraws consent for the processing of the User’s personal data; (iii) Upon request by a competent authority, where there is sufficient basis to determine that the processing of personal data affects the rights and interests of the User.

Purposes and Methods of Information Usage

NLT Group processes personal data for the following purposes:

1. To operate and provide services offered by NLT Group, including:

  • Providing services and features to You;
  • Delivering, maintaining, and improving NLT Group’s products and services.
  • Verifying the accuracy, truthfulness, and completeness of the information provided; assessing and categorizing risk levels in accordance with Vietnamese law;
  • Protecting Your rights in relation to the use of services and features provided by NLT Group. This includes the processing of information to facilitate the User in receiving entitlements through the services and features offered by NLT Group, as well as enabling related obligated parties to identify the User in order to minimize confusion when those entitlements are exercised;
  • Verifying User information and access rights throughout the process of account/service/product registration and usage (including the fulfillment of obligations under agreements or contracts—regardless of form—whether through interactions using services provided/co-provided by NLT Group or through written documents between the User and relevant authorities, organizations, or individuals as prescribed by law), as well as cooperation between NLT Group and the User;
  • Remembering information so that Users do not need to re-enter it during subsequent visits or when accessing the services again;
  • Communicating with Users and partners regarding accounts, services, and collaborative content via phone calls, SMS, emails, written documents, or other forms of communication;
  • Establishing service connections between the User’s account and third-party platforms or accounts (such linkage will be performed only with your consent in applicable cases);

  • To protect Users against fraudulent acts or misuse of User information, NLT Group may collect information about the User and their interactions, assess computers, mobile phones, and other devices used to access NLT Group’s services/applications/products to identify any software or activities that indicate potential violations or security breaches.

2. To fulfill regulatory compliance obligations and respond to requests from regulatory authorities in relation to NLT Group’s business operations.

3. To fulfill NLT Group’s commitments to data and information providers with whom Users have interactions (excluding personally identifiable information as defined by law); 

4. To manage access and implement security, safety, and integrity measures for the services provided by NLT Group to Users. 

5. To support Users: Based on the collected information, NLT Group carries out support activities to best address issues encountered by Users during service usage, such as handling inquiries, assisting with investigations, resolving complaints, monitoring, and improving customer support services,… 

6. Research and development: NLT Group may use the collected information to serve research and development purposes in order to improve service quality, manage and protect information and technical service systems, measure service performance, and enhance the products and services provided by NLT Group. 

7. Marketing and promotion: To promote and introduce products, services, promotional programs, research, surveys, news, updates, events, advertisements, and related content regarding the services of NLT Group and the services of partners cooperating with NLT Group. Specifically for the implementation of marketing, product introduction, and advertising activities: 

  • The advertising and product promotion activities (if any) shall be carried out through online/offline methods corresponding to the User’s approach;
  • The content and frequency of the advertising/promotion will be specifically provided by NLT Group in advertising programs. Depending on your access method, the advertising product content may be directly viewed after you click on the program/banner (or any equivalent form) for online advertising; or the advertising product content may be accessed by directly visiting the offline location to view/participate in the advertising/marketing activity. Through such access activities/interactions with the advertising product, the User agrees that you allow NLT Group to receive and process the information that you have provided/are providing/will provide for the purposes stated in this Privacy Policy..

In addition, the User also agrees that, depending on each advertising product, NLT Group, either independently or in collaboration with its partners, may set forth specific provisions to best support You and facilitate the implementation of the program.

8. Legal procedures and requirements NLT Group may use the collected information to investigate or resolve complaints or disputes related to the User’s use of services, or other activities permitted by applicable law.

How NLT Group Shares User Information

NLT Group may share User information in the following cases:: 

  • With Service Providers: NLT Group may share the User’s personal information with Service Providers to monitor and analyze the use of NLT Group’s Services, and to contact the User.
  • In case of business transfers: NLT Group may share or transfer the User’s personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of NLT Group’s business by another company.
  • With Affiliates: NLT Group may share your information with its affiliates, in which case NLT Group will require those affiliates to honor this Privacy Policy. Affiliates include subsidiaries, joint venture partners, or other companies that NLT Group controls or is under common control with.
  • With Business Partners: NLT Group may share the User’s information with NLT Group’s business partners to offer certain products, services, or promotional programs to the User.
  • With other users: when the User shares personal information or otherwise interacts in public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With the User’s Consent: NLT Group may disclose the User’s personal information for any other purpose with the User’s consent.
  • For Legal Reasons: NLT Group will share the User’s information with law enforcement agencies, public authorities, or other organizations if legally required to do so, or if such disclosure is reasonably necessary to: comply with legal obligations, procedures, or requests; enforce NLT Group’s Terms of Service and other agreements, policies, and standards, including investigating any potential violations thereof; detect, prevent, or address security, fraud, or technical issues; or protect the rights, property, or safety of NLT Group, its users, third parties, or the public as required or permitted by law (including the exchange of information with other companies and organizations for fraud prevention and risk reduction purposes).

Storage Space and Duration of User Information

  • User Information may be stored on servers outside the country where the User resides, such as in Vietnam, Singapore, Malaysia, or the United States. NLT Group maintains major servers around the world to provide you with our services seamlessly on a global scale.
  • The Company will only retain your Personal Data for as long as is necessary for the purposes set out in this Privacy Policy. NLT Group will retain and use your Personal Data as necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
  • The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of NLT Group’s services, or when NLT Group is legally obligated to retain this data for longer periods.

User Rights and Choices

  • Users have rights and choices regarding their information. Users may be granted certain rights under applicable law, which may include the right to access, delete, update, or correct their data; to be informed about the processing of their data; to file a complaint with competent authorities; and other rights. Users may appeal any decision we make regarding their request by following the instructions provided in the communication from NLT Group notifying them of our decision. Please refer to the Supplemental Terms below to determine whether your country has a local representative or contact person.
  • Users can access and edit most of their profile information by logging into the application/product/service provided by NLT Group. Users may delete history and the information they have provided, depending on the specific circumstances. We also provide tools in the Settings section to allow Users to control the information they provide and store, among other features. Users can delete their entire account in Settings if they choose to do so.

  • Users may refuse or disable Cookies by adjusting the settings in their browser on their device. Since each browser is different, please refer to the instructions provided by your browser. Note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps operate, Users may need to take different steps to opt out of targeted advertising Cookies in a browser and opt out of targeted advertising for a mobile app, which you can control through your device settings or mobile app permissions. Additionally, the User’s opt-out choice will apply only to the specific browser or device you are using at the time you opt out, so Users may need to opt out on each browser or device separately. If the User chooses to refuse, disable, or delete Cookies, certain functions of the Platform may no longer be available to the User.

Information Security and Disclaimer

NLT Group implements measures to ensure that your information is processed securely and in accordance with this policy. Unfortunately, the transmission of information over the Internet is not completely secure. While NLT Group will apply reasonable measures to protect your personal data—such as encryption—NLT Group cannot guarantee the security of your information transmitted through the Platform; any transmission of information is at your own risk.

NLT Group has appropriate technical and organizational measures in place to ensure a level of security appropriate to the varying risks and severity of potential impacts on the rights and freedoms of Users and other individuals. NLT Group maintains these organizational and technical measures and will revise them from time to time to enhance the overall security of its systems.

From time to time, NLT Group may include links to and from the websites of its partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that NLT Group does not accept any responsibility or liability for these policies. Please review these policies before you submit any information to these websites.

Links to Other Websites

NLT Group’s Services may contain links to other websites not operated by NLT Group. If the User clicks on a third-party link, the User will be directed to that third party’s website. NLT Group strongly advises the User to review the Privacy Policy of every website the User visits.

NLT Group has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party websites or services.

Privacy Policy Updates

NLT Group may update this Privacy Policy from time to time. When NLT Group updates the Privacy Policy, NLT Group will notify Users by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy or by providing any other notice as required under applicable law. The User’s continued access to or use of the Platform after the updated policy date constitutes the User’s acceptance of the updated policy. If the User does not agree with the updated policy, you must stop accessing or using the Platform.

Contact

All questions, comments, complaints, and requests regarding this Privacy Policy should be sent to the following address: kinhdoanh@nlt-group.com 

NLT Group will make every effort to resolve your request as soon as possible. This does not affect your right to lodge a complaint with the appropriate data protection authority, if applicable.

Supplemental Terms – Specific Legal Jurisdictions

In the event of any conflict between the provisions of the Supplemental Terms – Specific Legal Jurisdictions applicable to your jurisdiction and the remainder of this Policy, the provisions of the Supplemental Terms for your jurisdiction shall prevail and take effect.

Vietnam

If the User is using NLT Group’s services in Vietnam, the following supplemental terms shall apply. In the event of any conflict between the following terms and the provisions in the main section of this Policy, the following terms shall prevail.

Methods of Processing Personal Data. NLT Group may process the User’s personal data manually or automatically.

Rights and Obligations of the Data Subject. Except for certain specific exceptions, the User shall have rights and obligations in accordance with applicable laws. Specifically, the User has the following rights under the law:

  • Right to Know;
  • Right to Consent and Withdraw Consent;
  • Right of Access;
  • Right to Erasure of Data;
  • Right to Restrict Data Processing;
  • Right to Data Provision;
  • Right to Object to Data Processing;
  • Right to Complain, Denounce, or File a Lawsuit;
  • Right to Request Compensation for Damages; and
  • Right to Self-Protection.

The User may exercise these rights by contacting NLT Group using the details provided in the “Contact” section, and NLT Group will respond to the User’s request regardless of the location where the User’s data is stored.

User obligations under applicable law include:

  • Protecting their own personal data;
  • Requesting other relevant organizations and individuals to protect their personal data;
  • Respecting and protecting the personal data of others;
  • Providing complete and accurate personal data when consenting to the processing of their personal data;
  • Other obligations as prescribed by applicable laws.

Age, Parental and Guardian Consent. If the User is under 16 years old or is under guardianship:

  • The User must obtain consent from their parent(s) or legal guardian(s);
  • The parent(s) or legal guardian(s) of the User are responsible for: (i) all actions of the User related to their access to and use of the services; (ii) the User’s compliance with this policy; and (iii) ensuring that the User’s participation in the services will not, under any circumstances, result in any violation of applicable laws and regulations concerning child protection.
  • If the User does not have the consent of their parent(s) or legal guardian(s), or if the parent(s) or legal guardian(s) do not permit the creation of an account under their name, the User must cease accessing the product/application/service if the User is under the age of 16.