Information Security

Article 1: Introduction

1.1. Welcome to Golden SpoonS (including the Golden SpoonS website and mobile application) operated by Golden Gate Group Joint Stock Company and its affiliates (referred to individually or collectively as “Golden SpoonS”, “we”, or “our”). Golden SpoonS strictly complies with its responsibilities under applicable laws and regulations on information security (“Privacy Laws”) and is committed to respecting the privacy rights and concerns of all Users of the website and mobile application platforms (“Platforms”) (we collectively refer to the platforms and services we provide as described in the Platforms as the “Services”). “Users” are individuals who register an account with us to use the Services, including both Sellers and Buyers (referred to individually or collectively as “Users”, “you”, or “your”). We recognize the importance of the personal data you entrust to us and believe we have a responsibility to manage, protect, and process your personal data appropriately. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to help you understand how we collect, use, disclose, and/or process the personal data you provide to us and/or that we hold about you, whether currently or in the future, as well as to help you make informed decisions before providing us with any personal data.

1.2. “Personal Data” or “personal data” means data, whether accurate or not, about an individual from which the identity of the individual can be determined, either directly or indirectly, or from such data combined with other information to which an organization has or may have access. Common examples of personal data include names, identification numbers, and contact information.

1.3. By using the Services, registering an account with us, accessing the Platforms, or using the Services, you acknowledge and agree that you accept the methods, requirements, and/or policies described in this Privacy Policy, and hereby consent to our collection, use, disclosure, and/or processing of your personal data as described herein. IF YOU DO NOT AGREE TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORMS OR WEBSITE. If we change our Privacy Policy, we will notify you by posting those changes or the revised Privacy Policy on our Platforms. We reserve the right to amend this Privacy Policy at any time. To the maximum extent permitted by applicable law, your continued use of the Services or Platforms, including placing any orders, constitutes your acceptance of those changes or amendments to this Privacy Policy.

1.4. This Policy is applied concurrently with other notices, contractual terms, and consent terms related to our collection, storage, use, disclosure, and/or processing of your personal data and is not intended to replace any prior notices or terms unless otherwise stated.

1.5. This Privacy Policy applies to all Users of the Services, including both Buyers and Sellers unless otherwise stated.

Article 2: When will Golden SpoonS collect personal data?

2.1. We will/may collect personal data about you:

  • When you register and/or use our Services or Platforms, or open an account with us;

  • When you submit any forms, including but not limited to registration forms or other forms related to any of our products and services, online or otherwise;

  • When you enter into any agreements or provide documents or other information related to your interactions with us, or when you use our products and services;

  • When you interact with us, such as via phone calls (which may be recorded), letters, faxes, face-to-face meetings, social media platforms, and emails; including interactions with our customer service agents;

  • When you use our electronic services, interact with us through the application, or use services on our Platforms. This includes, but is not limited to, cookies that we may deploy when you interact with our Platforms or Website;

  • When you grant permission from your device to share information with our application or Platforms;

  • When you link your Golden SpoonS account to social media accounts or other accounts or use other social media features, according to the policies of the providers;

  • When you make transactions through our Services;

  • When you provide feedback or submit complaints to us;

  • When you register to participate in a contest;

  • When you provide us with your personal data for any reason.

The above list is not exhaustive and only highlights common situations when your personal data may be collected.

Article 3: What personal data will Golden SpoonS collect?

3.1. Personal data that Golden SpoonS may collect includes:

  • Full name

  • Email address

  • Date of birth

  • Billing and/or delivery address

  • Bank account and payment information

  • Phone number

  • Gender

  • Information sent by or related to the device(s) used to access our Services or Platforms

  • Images, audio data, or videos you share with us

  • Government-issued identification documents or other information necessary for our due diligence, customer identification, identity verification, or fraud prevention purposes

  • Marketing and communication data, such as your preferences when receiving marketing information from us and third parties, communication preferences, and your contact history with us, our service providers, and other third parties

  • Usage and transaction data, including details about your searches, orders, advertisements, and content you interact with on the Platform as well as other related products and services

  • Location data

  • Any other information about Users when they log in to use our Services or Platforms, and when using the Services or Platforms, including how they use our Services or Platforms

  • Aggregated data about the content Users use.

3.2. You agree not to provide us with any inaccurate or misleading information and agree to notify us of any inaccuracies or changes. We reserve the right to request additional necessary documents to verify the information you provide.

3.3. If you log in to become a User of our Platforms using your social media account (“Social Media Account”), link your Golden SpoonS account to your Social Media Account, or use any Golden SpoonS social media features, we have the right to access information you voluntarily provided to your Social Media Account service providers under their policies, and we will manage and use such personal data in accordance with this Policy at all times.

3.4. If you do not want us to collect the above personal information/data, you may opt out at any time by providing written notice to our Data Protection Officer. You can find more information about this in the section “How can you withdraw consent, request deletion, access, or correction of information you have provided to us?” below. However, please note that refusing or withdrawing consent to our collection, use, or processing of your personal data may affect your use of the Services and Platforms. For example, location-based services will not function if you do not allow the application to access your location.

 

Article 4: Collection of Other Data

4.1. Like most websites and other mobile applications, information sent from your device may contain data about you that is recorded by a web server when you use our Platforms. This information includes IP address, operating system of your computer/mobile device, browser type, mobile device type, characteristics of your mobile device, the unified device identifier (UDID) or mobile equipment identifier (MEID) of your mobile device, referring website address (if any), pages you have visited on our website or mobile app, access times, and sometimes “cookies” (which can be disabled using your browser settings) to help the website remember your last visit. If you are logged in, this information is linked to your personal account. This information is also included in anonymous statistical data to help us understand how visitors use our Website.

4.2. Our mobile applications may collect precise location information of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose, and/or process this information for one or more purposes, including providing location-based services you request, delivering content relevant to you based on your location, or allowing you to share your location with other Users as part of the Services provided by our mobile applications. For most mobile devices, you can withdraw permission for us to collect location-based information through device settings. If you have questions about disabling location services on your mobile device, please contact your mobile service provider or device manufacturer.

4.3. When you view pages on our website or mobile app, view content and advertisements, or access other software on our Platforms or through the Services, much of the same information is sent to us (including IP address, operating system, etc.); however, instead of page views, your device sends us information about the content, ads viewed, and/or software installed on the Services and Platforms, as well as timing information.

Article 5: Cookies

5.1. We or our authorized service providers and advertising partners may sometimes use “cookies” or other features to allow us or third parties to collect or share information related to your use of our Services or Platforms. These features help us improve our Platforms and Services, enable us to offer new services and features, and/or allow us and our advertising partners to provide content better suited to your interests through remarketing. “Cookies” are identifiers stored on your computer or mobile device that record data about the computer or device, the Services or Platforms used or visited, when and how they were used, the number of visitors, and other activities on the Platforms. We may link cookie information with personal data. Cookies also link to information about products you select and websites you have visited. This information is used to track your shopping cart, deliver content tailored to your preferences, enable our third-party advertising partners to serve ads on websites, perform data analytics, and manage the use of Services.

5.2. You can refuse cookies by adjusting your browser or device settings accordingly. However, please note that if you do so, you may not be able to use all functions of our Platforms or Services.

Article 6: How Do We Use the Information You Provide to Us?

6.1. We may collect, use, disclose, and/or process your personal data for the following purposes:

  • To review and/or process your application/transaction with us or transactions or correspondence with third parties via the Services;

  • To manage, operate, provide, and/or administer your use and/or access to our Services and Platforms (including your preferences), as well as your relationship and user account with us;

  • To respond to, process, resolve, or complete a transaction and/or fulfill your requests for certain products and services, and notify you about service issues and unusual account activities;

  • To enforce our Terms of Service or any applicable end-user license agreements;

  • To protect the personal safety and rights, property, or safety of others;

  • For identification, verification; legal assessment, or understanding your customer purposes;

  • To maintain and manage any software updates and/or other updates and support that may be required from time to time to ensure our Services operate smoothly;

  • To facilitate customer service, fulfill your requests, resolve or respond to any inquiries submitted by (or on behalf of) you;

  • To contact or communicate with you via phone, text message and/or fax, email and/or mail or otherwise for administrative purposes and/or to manage your relationship with us or your use of our Services, such as communicating administrative information related to our Services. You acknowledge and agree that such communication may be conducted by postal mail, documents or notices which may disclose certain personal data about you to provide such documents, including on packaging/envelopes;

  • To enable other users to interact, connect with you or see some of your activities on the Platform, including notifying you when another user sends you a private message, posts comments to you on the Platform, or connects with you through social features on the Platform;

  • To conduct research, analysis, and development activities (including data analysis, surveys, product and service development and/or profiling), to analyze how you use our Services, to suggest products and/or Services that fit your interests, to improve our Services or products and/or enhance your customer experience;

  • To facilitate audits and surveys, among other activities, to validate the size and composition of the target audience, and understand their experiences with Golden SpoonS Services;

  • For marketing and advertising purposes, including sending you marketing communications and promotional materials about products and/or services (including third-party products and/or services that Golden SpoonS may cooperate with or affiliate) that Golden SpoonS (and/or its affiliates or related groups) may sell, market or promote, whether such products or services currently exist or will be created in the future. You may unsubscribe from marketing communications at any time using the unsubscribe function in electronic marketing materials. We may use your contact information to send newsletters or marketing materials from us or related companies;

  • In accordance with applicable laws, and requests from competent government authorities; or if we believe disclosure is necessary, including but not limited to comply with legal requirements for disclosure under any applicable law governing Golden SpoonS or related companies (including, if applicable, disclosing your name, contact information, and company information);

  • To compile statistics and conduct research for reporting requirements and/or maintain internal books or regulatory compliance;

  • To perform due diligence or screening activities (including but not limited to background checks) in compliance with legal obligations or our risk control procedures, whether legally required or voluntarily applied;

  • To audit our Services or Golden SpoonS business operations;

  • To prevent or investigate any fraud, unlawful activities, deficiencies, or misconduct, whether occurred or suspected, related to your use of our Services or any issues arising from your relationship with us;

  • To respond to any factual or threatening complaints made against Golden SpoonS or other complaints infringing the rights of third parties;

  • To store, host, back up (whether for disaster recovery or other purposes) your personal data;

  • To process and/or facilitate a business asset transaction or potential business asset transaction involving Golden SpoonS as a party or involving any Golden SpoonS affiliate or related companies, and possibly other third-party organizations participating in such transaction. “Business asset transaction” includes purchases, sales, leases, mergers, acquisitions, liquidations, or financing of an organization or part thereof or any business or assets of an organization; and/or

  • Any other purposes we notify you of at the time we seek your consent

(collectively referred to as “Purposes”)

6.2. Users acknowledge, permit, and agree that Golden SpoonS may access, maintain, and disclose User Account information and Content where required by law or pursuant to court orders or requests from governmental or competent authorities requiring Golden SpoonS to do so, or where such maintenance or disclosure is reasonably necessary: (a) to comply with legal processes; (b) to comply with requests from government or competent authorities; (c) to enforce Golden SpoonS Terms of Service or Privacy Policy; (d) to respond to factual or threatening complaints against Golden SpoonS or complaints infringing third party rights; (e) to respond to User inquiries related to customer care; or (f) to protect the rights, property or safety of Golden SpoonS, Users, and/or the community.

6.3. For the Purposes for which we collect, use, disclose, or process your personal data, depending on the actual circumstances, such purposes may not be listed above. However, we will notify you of any such additional purposes at the time we seek your consent, unless processing is permitted without your consent under applicable privacy or personal data protection laws.

Article 7: How Does Golden SpoonS Protect and Store Customer Information?

7.1. We implement various security measures and continuously strive to ensure the safety of your personal data within our systems. User personal data is stored behind secure networks and can only be accessed by a limited number of personnel with special access rights to our systems. However, absolute security cannot be guaranteed.

7.2. We will retain personal data in accordance with applicable laws on personal data protection and/or other current laws. This means we will destroy or delete your personal data when we reasonably determine that (i) retention no longer serves the original collection purpose; (ii) retention is no longer necessary for any legitimate or business purposes; and (iii) there are no other legitimate interests to continue holding such personal data. If you stop using our Platforms, or your rights to use the Platforms and/or Services are terminated or revoked, we may continue to store, use, and/or disclose your personal data in accordance with this Privacy Policy and our legal obligations under applicable personal data protection laws. Depending on applicable laws, we may securely destroy your personal data without prior notice to you.

Article 8: Does Golden SpoonS disclose information collected from visitors to other parties?

8.1. During business operations, we will/may need to disclose your personal data to third-party service providers, agents, and/or our affiliates or related companies, and/or other third parties, for one or more of the Purposes mentioned above, and such disclosure will be made in accordance with the procedures and regulations of applicable laws. These third-party service providers, agents, and/or our affiliates or related companies and/or other third parties will process your personal data either on our behalf or otherwise, for one or more of the Purposes mentioned above. Such third parties include, but are not limited to:

  • Our subsidiaries, affiliates, and related companies;

  • Sellers or buyers with whom you have transactions or interactions on the Platform or related to your use of the Services for the aforementioned purposes;

  • Other users on our Platform for one or more of the aforementioned purposes;

  • Contractors, agents, service providers, and other third parties we engage to support our business operations. These parties include, but are not limited to, providers of administrative or other services such as postal companies, shipping service providers, financial service providers, advertising and marketing partners, telecommunications companies, IT companies, and data centers;

  • Government agencies or state authorities with jurisdiction over Golden SpoonS or other parties authorized as stated in Article 6.2;

  • Buyers or other successors in the event of mergers, divestments, restructuring, reorganization, dissolution, or sale or transfer of part or all of Golden SpoonS’s assets, whether ongoing or under bankruptcy, liquidation, or similar procedures, where the personal data Golden SpoonS holds about our users are included in the transferred assets; or to a partner party in a business asset transaction in which Golden SpoonS or any of its affiliates or related companies participates; and

  • Third parties to whom we disclose information for one or more Purposes, and such third parties in turn collect and process your personal data for one or more Purposes.

8.2. We may share user information, including statistical and demographic data about users and information about their use of the Services, with advertising partners and third-party advertising providers for remarketing and/or other programs.

8.3. To avoid doubt, in cases where laws on the protection of personal information confidentiality or other applicable laws permit an organization like us to collect, use, or disclose your personal data without your consent, such legal permissions shall continue to apply. In accordance with these regulations and legal provisions, we may use your personal data to establish legal bases including compliance with our legal obligations, to perform contracts with you, to achieve legitimate interests and reasons where our use of your information outweighs any harm to your data protection rights, or when necessary in relation to legal claims.

8.4. Third parties may intercept or unlawfully access personal data transmitted to or held on the website; technologies may malfunction or not operate as expected; or others may access, misuse, or abuse information without our fault. However, we will implement appropriate security measures to protect your personal data in accordance with laws protecting personal information confidentiality; however, absolute security cannot be guaranteed, such as in cases of unauthorized disclosure resulting from malicious hacking activities or complex malicious content beyond our control.

8.5. As stipulated in Golden SpoonS’s Terms of Service, users who own personal data of other users through the use of the Services (“Recipient”) hereby agree that they will (i) comply with all applicable personal data protection laws related to any such data; (ii) allow the user whose personal data the Recipient has collected (“Discloser”) to delete their collected data from the Recipient’s database; and (iii) allow the Discloser to review what information the Recipient has collected about them, in each of cases (ii) and (iii) above, subject to and as required by applicable laws.

8.6. In addition to the above, Users receiving any personal data of other Users related to the use of the Services must comply with all applicable privacy laws and regarding any personal data of the Discloser received from Golden SpoonS, (i) must not use such personal data except reasonably necessary to respond to, process, resolve, or complete a transaction, except with prior written consent of the Discloser and Golden SpoonS; (ii) must not contact Users using that information outside of the Golden SpoonS platform; (iii) must not disclose the Discloser’s personal data to any unauthorized third parties without prior written consent from the Discloser and Golden SpoonS; (iv) must use full security measures to protect the personal data of each Golden SpoonS User they hold and delete such data as soon as possible after completing the transaction; and (v) must notify Golden SpoonS’s Personal Data Protection Officer at [HERE] in case of possible data breaches or loss of such User data.

Article 9: Information about Children

9.1. These Services are not intended for children under 13 years old. We do not knowingly collect or retain any personal data or personally identifiable information of anyone under 13 years old. No part of our Platform or other Services is intended for children under 13 years old. Parents or guardians of children under 13 are kindly requested to supervise and ensure that the personal information of the children they are responsible for is not submitted to Golden SpoonS. In the event that personal information of children under 13 is provided to Golden SpoonS by such parents or guardians, the parents or guardians consent to the processing of the child’s information and agree to be bound by this Policy on behalf of the child. We will suspend any accounts used solely by such children and will remove and/or delete any personal data we believe was submitted by any child under 13 years old.

Article 10: Information Collected by Third Parties

10.1. Our platform uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your device, to help the Platform analyze how users use our Platform. Information generated by the cookie about your use of the Platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to evaluate your use of our Platform, compile reports on website activity for website operators, and provide 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.

10.2. We, and third parties, may in some cases provide downloadable software applications for you to use on or through the Platform or Services. These applications may have separate access and allow third parties to view your identifying information such as your name, user ID, your device’s IP address, or other information such as the game you are playing during any specific session, and any cookies previously installed or installed for you by a third-party software application or website. Additionally, these applications may require you to provide further information directly to third parties. Third-party products or services provided through these applications are not owned or controlled by Golden SpoonS. You should read the terms and other policies published by those third parties on their websites or elsewhere.

Article 11: Disclaimer Regarding Security Obligations and Third-Party Websites

11.1. WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION YOU PROVIDE ON THIRD-PARTY WEBSITES. We take various security measures to maintain the safety of your personal data that we store or control. Your personal data is stored behind secure networks and is only accessible by a limited number of individuals with special access rights to our systems, and who have been required to keep the data confidential. When you place orders or access your personal data, we recommend using a secure server. All personal data or personal information you provide is encrypted into our databases to be accessed only as described above.

11.2. To provide added value to you, we may select various third-party websites, applications, or services to link to or embed within the Platform. We may also engage in co-marketing relationships and other arrangements to provide e-commerce services and other services and features to visitors. These linked sites have their own privacy policies as well as separate and independent security measures. Even if those third parties are linked with us, we do not control these linked websites/applications/services, each of which has its own privacy protection and data collection practices, independent from us. Data collected by our co-marketing partners or third-party websites/applications/services (even if provided on or through our Platform) may not be accessible to or retained by us.

11.3. Therefore, we assume no responsibility or legal liability for the content, security measures (or lack thereof), and activities of these linked websites/applications/services. These linked websites/applications/services are provided for your convenience only, and you access them at your own risk. However, we strive to maintain the integrity of our Platform and the links placed on each such website and therefore welcome feedback regarding these linked websites (including if a particular website is not functioning).

Article 12: Does Golden SpoonS Transfer Your Information Overseas?

12.1. Your personal data and/or other information may be transferred, stored, or processed outside the territory of your country. In most cases, your personal data will be processed in Vietnam, where our servers are located. Golden SpoonS only transfers your information overseas in accordance with the provisions of the law.

Article 13: How Can You Withdraw Consent, Request Access, or Correct the Information You Have Provided to Us?

13.1. Withdrawal of Consent

13.1.1. You may withdraw your consent for the collection, use, and/or disclosure of your personal data that we hold or control by sending an email to our Personal Data Protection Department at [email protected], and we will handle such requests in accordance with this Privacy Policy and relevant laws.

13.1.2. We may periodically send you newsletters and direct marketing emails about our Services if you have subscribed to receive such communications. You have the option to “opt out” (for example, by following the unsubscribe instructions provided in the emails you receive). However, we need to send you certain communications related to us or our services, and you will not be able to opt out of receiving such communications (such as updates to our Terms of Service, this Privacy Policy, billing or payment information, or customer service messages).

13.2. Additional Notice to Users Whose Personal Data is Subject to California Law

13.2.1. For the purposes of the California Consumer Privacy Act (“CCPA”), we do not “sell” personal information and in the twelve months prior to the effective date of this Policy, we have not sold any personal information of our users and/or prospective candidates as defined by the CCPA. California’s “Shine the Light” law also allows California residents, under certain circumstances, to opt out of the sharing of some types of personal information (as defined in that law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

13.2.2. Personal information collected, used, and/or disclosed by Golden SpoonS, and collected, used, and/or disclosed from users and/or prospective candidates in the twelve months prior to the effective date of this Policy, may include personal information as defined under CCPA, depending on how you accessed the Website and interacted with us.

13.2.3. Under CCPA or other applicable laws, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of your personal information or request that we send it to another company; (iv) restrict our use of your personal information, including the right to opt-in or opt-out of the sale of your personal information to third parties, depending on applicable law; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and (vi) request Golden SpoonS to delete personal information about you, subject to certain exceptions provided by law.

13.2.4. If you wish to exercise any of these rights, please contact us as provided below by emailing our Personal Data Protection Officer at [email protected]. We will handle such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before acting on your request. If you are a California resident, you have the right not to be discriminated against for exercising your rights under the CCPA.

13.3. Other User Rights

13.3.1. If you reside in the European Economic Area, you have the right to exercise certain rights available under applicable data protection laws. We will comply with requests to exercise these rights as required by applicable law. Please note that in some cases, we may need to continue processing your information due to legitimate interests or legal obligations. You also have the right to lodge a complaint with supervisory authorities if you believe our processing of your personal data violates applicable law.

13.3.2. For Canadian residents: Under this Privacy Policy, if we transfer your personal information to another country, such personal information may be disclosed to foreign governments or governmental agencies pursuant to lawful orders issued in that foreign country for purposes other than those described in this Policy.

13.4. Requesting Access to or Correction of Personal Data

13.4.1. You may request access to and/or correction of your personal data that we hold or control by submitting a written request. We will require sufficient information from you to verify your identity and the nature of your request in order to address it. Please submit your written request by emailing our Data Management Officer at [email protected].

13.4.2. We may charge a reasonable fee to process your request for access to personal data (if any). If a fee applies, we will provide you with a written estimate. Please note that in most jurisdictions, we are not obligated to respond to or comply with your access request unless you agree to pay the fee.

13.4.3. We reserve the right to refuse correction of your personal data under applicable laws protecting personal data confidentiality, in cases where the laws permit or require us to do so.

13.4.4. Please note that certain information may be exempt from such requests under applicable law, and depending on your data choices, certain services may be limited or unavailable. We will not discriminate against you for exercising your rights.

Article 14: Questions, Concerns, or Complaints? Contact Us

14.1 If you have any questions or complaints regarding our privacy protection practices, please contact us at [email protected].

Information Collection and Management Unit: Golden Gate Group Joint Stock Company

Address: No. 60, Giang Van Minh Street, Doi Can Ward, Ba Dinh District, Hanoi City