PRIVACY POLICY

1. Introduction

This Privacy Policy/ Personal Data Protection Policy ("Privacy Policy" or "Policy") is designed by Lock & Lock HCM Co., Ltd ("LocknLock" or "We") to help customers ("Customers") understand how we collect, use, protect, disclose and/or process personal data that Customers have provided to us through the use of the website with the domain name https://www.locknlock.vn/ ("Website") for shopping or sharing information with us whether now or in the future, as well as to help Customers make informed decisions before providing us with any of their personal data.

We, Lock & Lock HCM Co., Ltd, always commit to ensuring our Customers that we are always serious in fulfilling our responsibilities regarding information security in accordance with the regulations on the protection of personal information confidentiality under Vietnamese law and commit to respecting the privacy and concerns of all Customers regarding LocknLock's Website.

By accessing, using the Website and/or signing up as a member, Customers agree with us that they accept the methods, requirements and/or policies described in this Privacy Policy and hereby acknowledge that they are fully aware of and consent to LocknLock collecting, using, disclosing and/or processing their personal data as described in Section 2 of this Policy.

Please read this Policy carefully, as our business operations will continuously develop, our Personal Data Protection Policies, Website and Terms of Use may also be updated continuously. Customer's use and/or continued use of our products, services are understood as Customers accepting the updated Privacy Policy. Customers agree that they are responsible for regularly checking for any updates or changes to this Privacy Policy. Unless otherwise provided, Our current Policy applies to all information we have about Customers and Customers' accounts, including but not limited to Customers' personal information and/or any information, data that we may obtain from Customers through the Website. Customers' access to our Website and any privacy disputes shall be governed by this Privacy Policy.

This policy is applied in conjunction with notices, contractual terms, other applicable consent terms relating to our collection, storage, use, protection, disclosure and/or processing of Customers' personal data.

We reserve the right to modify this Policy at any time within the scope permitted by applicable laws and regulations. We will notify Customer of any material changes to this Policy by posting it on the Website or by any other means we deem appropriate. The amended Policy will be effective when Customers are notified in a reasonable manner according to our regulations or when it is posted on the Website.

2. Definitions

"Personal data" refers to information in the form of symbols, writing, numbers, images, sounds or similar forms in the electronic environment associated with a specific individual or aiding in identifying a specific individual. Personal data includes basic personal data and sensitive personal data specifically regulated in Decree No. 13/2023/ND-CP and may be amended, supplemented or replaced by subsequent effective documents.

"Processing of personal data" refers to one or more activities affecting personal data, such as: collection, recording, analysis, verification, storage, modification, disclosure, combination, access, retrieval, retrieval, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction of personal data or other related actions.

3. Personal data

Timing of personal data collection

LocknLock will collect personal data about Customers when:

  • Customers sign up and/or use our website or open an account on that website;

  • Customers make purchases of products on our website;

  • Customers interact with us through telephone calls (which may be recorded), letters, conversations on the Website and/or via email;

  • Customers provide feedback or complaints to us;

  • Customers submit their personal data to us for any reason;

  • Customers engage in other activities on our Website.

  • And/or any other cases as determined by us and/or current legal regulations.

Note: The cases we mention here are not intended to list all possible cases but are only common cases of personal data collection.

Collected personal data

During the Customer's use of the Website and depending on our decision to upgrade the functionality of the Website to include online shopping functionality through an online personal account, at each moment, we may collect and process the following Personal Data:

  • Identification information including user identification, profile pictures, usernames (nicknames) or similar identification information, date of birth and gender;

  • Contact information including name, email address and phone number;

  • Transaction data including payments to or from the Customer and details of the products and services purchased by the Customer from us and the information Customer enter on the Website when Customer register for events, participate in promotional programs organized by us, for example, Customer’s name, email address, phone number and products purchased by the Customer;

  • Customer account login data, browser type and version, timezone and region configuration, location data of our stores where the Customer registers the location, browser plugin type and version, operating system, platform and other technology on the device used to access the Website;

  • Account profile data including user identification information, usernames (nicknames), passwords, any purchase transactions or orders of the Customer, preferences, priorities, feedback and survey evaluation opinions of the Customer;

  • Usage data including information about how the Customer uses our Website and services, products;

  • Marketing and communication data including preferences for receiving marketing information from us and preferences for how to receive that marketing information;

  • Basic personal data defined in Decree No. 13/2023/ND-CP and other effective legal documents on personal data (if any).

4. Purposes of personal data collection

LocknLock uses Customer information, including but not limited to, for the following purposes:

  • Creating and managing Customer accounts on LocknLock's website;

  • Serving the purpose of identification, verification, legal assessment or to recognize Customers;

  • Providing Customers with the best and quickest customer support;

  • Facilitating and enhancing the use of the website to carry out shopping for LocknLock brand products;

  • Allowing Customers to participate in contests or promotional programs;

  • Handling delivery to Customers and returns in case of exchanges;

  • Processing payments from Customers and issuing refunds (if any);

  • Conducting research and analysis on Customer use or interest in the Website, products and content provided by us or evaluation content provided by Customers through our Website;

  • Conducting research, operating, evaluating and improving our products and business operations;

  • Providing Customers with information about products, goods that Customers have requested or agreed upon beforehand, product information may be sent via email or messages to Customers.

  • Responding to comments and/or questions from Customers;

  • Resolving or facilitating convenient conditions for customer service, executing Customer instructions, resolving or responding to any inquiries sent by (or intended to be sent by) Customers or on behalf of Customers;

  • Contacting Customers via telephone, text messages and/or fax, email and/or mail or other means for administrative and/or customer relationship management purposes or for Customers using our Website to carry out shopping;

  • Meeting legal procedures or to comply with or pursuant to current legal regulations and requests from competent state authorities or requests from any judicial authority or when we truly believe that disclosure of information is necessary, including but not limited to, meeting disclosure requests as required by any laws binding LocknLock

  • Enforcing Terms of Use, Terms and Conditions;

  • Managing business activities;

  • Performing functions in other ways for Customers at the time of collection;

  • As requested by law or permitted by law.

  • For other purposes related to the operation of the website, policies, programs according to our business activities...

For the Purposes for which we have, are and will collect, use, disclose, protect or process the personal data of customers depends on the current circumstances, that purpose may not be explicitly stated above. However, we will inform customers of other purposes at the time of requesting customer permission, unless the processing of data without customer consent is permitted by the provisions of the law on the protection of personal information or other legal regulations.

5. Provision of personal data by Customers

Personal data collected with the clear consent of Customers shall only be used for activities specified in this Policy, except in the following cases:

  • A separate agreement between Us and Customers regarding the use of personal information for purposes and scope beyond those clearly defined in this Policy.

  • We provide products or services at the request of Customers.

  • We fulfill our obligations under the law and current regulations.

Customers hereby agree not to provide us with any false or misleading information and also agree to notify and update us of any inaccurate or changing information. We reserve the right, at our discretion, to request documents or texts deemed necessary to verify any information provided by Customers.

In case Customers do not agree to provide personal data and do not agree to allow us to collect and process the personal data information mentioned in this Policy, Customers may not participate/create an account on our website. For Customers who have provided personal data, we will send notifications in writing via Our email address.

However, please note that refusing or revoking permission for us to collect, use or process Customers' personal data may affect Customers' use of the website for their shopping.

6. Data retention period

Customer information will be stored by us for the duration of the account's existence. For accounts that have become inactive, we will still retain the personal information and access of Customers to serve the purposes of fraud prevention, investigation, addressing inquiries and other requests related to the purchase history of Customers.

We will store or retain Personal Data obtained in electronic form recorded by our servers or servers of third parties contracting with us (if any).

7. Processing of personal data

Depending on the purpose of collecting personal information, we will perform one or more activities affecting Customers' personal data, including but not limited to: collecting, recording, analyzing, verifying, storing, disclosing, combining, accessing, retrieving, retrieving, encrypting, decrypting, copying, sharing, transmitting, providing, transferring, deleting, destroying personal data or other related actions permitted by law. Processing activities of Customer's personal data may be carried out by us through automated or manual methods or by any other method that we deem appropriate.

8. Data protection and deletion, adjustment of personal data

Personal data protection

We ensure appropriate measures to ensure the safety and security of the Personal Data collected from Customers, preventing theft or unauthorized use, unauthorized access, modification or destruction of Customer's Personal Data.

Cancellation, deletion and adjustment of Personal Data

We will maintain personal data in compliance with the regulations of data protection laws and/or other applicable laws. We will delete or erase personal data when requested by the Customer in accordance with legal requirements or when we have a reasonable basis to determine that (i) storage is no longer necessary for any purpose of collecting that personal data, (ii) storage is no longer necessary for any lawful purpose or business purpose; (iii) there are no other legitimate interests to continue retaining this personal data. If the Customer stops using our Website or Customer’s rights to use the Website are terminated or revoked, we may continue to store, use according to this Privacy Policy and fulfill our obligations under applicable data protection laws. Depending on legal requirements, we may securely destroy Customer's personal data without prior notice and consent of the Customer.

We reserve the right to delete, destroy personal data in cases where requests from the Customer do not comply with the current legal regulations or cases where we are not allowed to delete under legal regulations.

Customers have the right to request Us to update, adjust or delete their personal information that we hold, subject to certain exceptional cases as prescribed by law, by sending an email, updating on the Customer's personal account provided on the Website or by written request to us via contact information. We may request certain specific personal information to verify the identity of the requester.

9. Transfer of Personal data abroad

In addition to using Customer's Information and/or personal data within the country, we may transfer Information and/or personal data abroad specifically transferring Personal Data to the parent company of LocknLock ("Lock & Lock Co., Ltd") for storage or processing for reporting purposes, conducting analysis to evaluate our business activities in Vietnam and/or have other purposes as appropriate and permitted by law. We will only transfer Customers’s personal data abroad in compliance with the regulations of personal data protection laws and this Policy.

When transferring Customer's Personal Data abroad, we will take appropriate protective measures according to the law and current regulations to protect Customer's Personal Data. We will take necessary actions to ensure that Personal Data complies with the regulations of Vietnamese law as well as South Korean law where the LocknLock Corporation is headquartered. Personal data will be protected by measures at least equivalent to those prescribed by Vietnamese law. In South Korea, Personal Data is subject to the regulation of South Korean law; courts, government, administrative agencies, management agencies and security agencies of South Korea may access Customer's Personal Data without notifying the Customer.

10. Individuals and Organizations That May Access Information

In Vietnam, LocknLock's legal entity controlling Customer's personal data is Lock & Lock HCM Co., Ltd.

We may share (or permit sharing) Customer’s personal data and/or transfer customer's personal data to third parties and/or our affiliates for the purposes mentioned in this Privacy Policy. Third parties and affiliates may be present in or outside Vietnam, including but not limited to:

  • Companies that are members of the LocknLock Group;

  • Service providers (e.g., agents, retailers, contractors and partners in fields such as payment services, transportation and delivery services, marketing, customer data analysis or research, social media, customer service, installation services, information technology and web hosting services);

  • Service providers and their related companies; and

  • Website and App users (if any) or other Services.

  • When disclosing Customer’s personal data to third parties, we ensure that third parties and our affiliates will safeguard Customer’s personal data from unauthorized access, collection, use, disclosure, unauthorized data processing or similar risks and only retain Customer’s personal data for the necessary period to achieve the purposes mentioned above.

  • We may also share personal data in connection with any acquisition, merger or any acquisition in our business activities, provided that we meet the requirements of data protection laws applicable when disclosing Customer’s personal data.

  • We may transfer or permit the transfer of Customer’s personal data outside Vietnam for any purposes specified in this Privacy Policy. However, we will not transfer or permit any personal data of Customer’s to be transferred outside Vietnam unless such transfer of personal data complies with the regulations of the applicable law.

  • We may share Customer’s personal data with third-party service providers or our affiliates (e.g., payment service providers) for them to provide services to Customer beyond the services Customer use on our Website and App or our Services. Customers’s agreement to use services from third-party service providers or our affiliates will be subject to the terms and conditions agreed upon between Customers and the third-party service provider or our affiliate. When Customer agree to the provision of services by third-party service providers or our affiliates, the collection, use, disclosure, storage, transfer and processing of Customers’s personal data (including Customers’s personal data and any data disclosed by us to the third-party service provider or affiliate) must comply with the applicable privacy policy of the third-party service provider or our affiliate, who will be the data controller of the data provided. Customers agree that any inquiries or complaints related to Customers’s agreement to use services from third-party service providers or our affiliates will be forwarded to the entity named in the applicable privacy policy.

11. Rights and Responsibilities of Customers under the Privacy Policy

  • Depending on our decision to upgrade the functionality of the Website to include online shopping through an online personal account, Customers have the following rights regarding their Personal Data:

  • Be informed about the processing activities of their personal information.

  • Request access to their Personal Data. Customers may request copies of the data we hold and may confirm that we are processing their Personal Data lawfully.

  • Request correction of their Personal Data when the information is incomplete or inaccurate. However, in this case, we may need to verify the accuracy of the new information provided by the Customers.

  • Request withdrawal of their consent in accordance with the procedures specified in this Policy and/or as provided by applicable law.

  • Request that we delete their Personal Data, subject to the provisions of the law and this Privacy Policy. However, at the time of invoicing, we may not always be able to comply with Customers’s deletion request for certain legal reasons (Customer will be notified if applicable).

  • Request the restriction of processing of their personal information in accordance with the provisions of the law and this Policy.

  • Object to the processing of their Personal Data if the processing by us or any third party processing the Personal Data makes the Customers feel that it affects their fundamental rights or freedoms in specific situations they are placed in. Customers may object to the processing of this Personal Data.

  • Withdraw their consent if they do not agree to the processing of Personal Data mentioned in this policy. However, this will not affect the legality of the processing of Personal Data before the Customers withdraws their consent. Additionally, Customers acknowledge that if they withdraw their consent, we may not be able to provide them with a specific product or service. In such cases, we will notify Customers’s when the Customers withdraws their consent.

  • Complain, report or litigate in accordance with the law.

  • Request compensation for damages as provided by law in case of violation of provisions on personal data protection, except as provided in this Policy and/or other provisions of the law.

  • Comply with the provisions stated in this Policy.

  • Comply with the laws on personal data protection and participate in preventing and combating violations of provisions on personal data protection.

12. Our contact information

If Customer have any questions about personal data protection or data privacy rights, please refer to our list of frequently asked questions about data protection/privacy rights.

If Customer’s query is not addressed in our Frequently Asked Questions or if Customer have any questions or complaints about this Privacy Policy or how we handle Customer’s personal data, please contact us through our online chat function or using the following contact information:

LOCK & LOCK HCM CO., LTD.

9th Floor, 77 Hoang Van Thai, Tan Phu Ward, District 7, Ho Chi Minh City, Vietnam

Tel: 028 54135750 – Fax: 028 54135756

Mail: adminonline@locknlock.com