I. General Principles
1. Definitions and interpretation
1.1. Definitions
The capital terms under this Usage Terms and Privacy Policy, unless defined in the context herein, shall be defined as follows:
“The Company” or “we” or “us” refers to MAI and the ES.
“Privacy Policy” means this Website Usage Terms and Privacy Policy.
“ES” means MAI’s subsidiaries, affiliates, companies within the corporate group model.
“User” or “you” includes customers, investors, agents, suppliers, partners, contractors, service providers and candidates who use the Interactive Channel and/or provide their information thereof.
“Interactive Channel” means this website, other websites and groups on social networks (such as Facebook, Instagram, Twitter) owned, and/or managed, governed by the Company.
“MAI” means Masterise Aviation Infrastructure Joint Stock Company.
“User Information” means any information, data that can be used to identify the User and/or upon which the User is identified and/or other information that User provided on the Interactive Channel, including but not limited to name, nationality, telephone number, email address, name of the company, title, photo, ID card/citizen identity card, date of birth and access history, etc. User Information includes basic and sensitive personal data as prescribed by laws.
“Process” means the method the Company processes the User Information in accordance with the laws.
1.2. Interpretation
The definitions in this Privacy Policy apply equally to the singular and plural forms of defined terms. The words “include” will be considered to be accompanied by the word “without limitation to”.
2. This Privacy Policy describes:
a) how our Interactive Channel operates;
b) how the User uses our Interactive Channel;
c) emerged risks when User using our Interactive Channel;
d) our Cookies policy; and
e) how the Company Process and keeps confidential of User Information in the progress of accessing, using and providing information on Interactive Channel. Including:
i. User Information we collect
ii. How we store and protect User Information
iii. How we use User Information
iv. How we share User Information
v. Your rights and invocation of such rights
vi. Contacts, notices and revisions
3. Privacy Policy does not apply to any services, products, websites, or content that are offered by third parties or have their own privacy policy.
4. Privacy Policy is made bilingual in Vietnamese and English, in the event of any discrepancy between Vietnamese version and English version, the Vietnamese version shall prevail.
II. Usage Terms
1. Consent to Privacy Policy
By using the Interactive Channel, User confirms his/her consent and agreement to be governed by the prevailing Privacy Policy. If not, please cease your usage on the Interactive Channel.
Certain content may be subject to additional conditions (“Special Conditions”) and will be accepted by the User upon each access. In the event of any inconsistency between the Privacy Policy and the Special Conditions, the Special Conditions shall prevail.
2. Access to the Interactive Channel
Access is granted on a temporary basis and may be modified or discontinued without prior notice. The Company reserves the right to restrict access for any reason, including breach of the terms, misuse, or for maintenance purposes.
We do not warrant that the Interactive Channel will operate continuously, uninterruptedly, or securely, and shall not be liable in the event the Interactive Channel is disrupted or inaccessible.
3. Use of the Interactive Channel
The User is solely responsible for the use of the Interactive Channel and shall ensure that any persons who share the User’s internet connection are aware of and comply with these terms.
Where the User is provided with a username, password, or similar credentials, the User is responsible for maintaining their confidentiality and for preventing any unauthorized disclosure. We reserve the right to disable the account if the User shows signs of violation.
The User undertakes not to engage in any acts that may harm the Interactive Channel, the Company’s reputation, or interfere with other users’ access to the Interactive Channel, and shall not intentionally transmit viruses or gain unauthorized access. Any violations will be reported to the competent authorities and the User’s access will be terminated.
4. Content
We do not warrant the accuracy, completeness, or timeliness of the content. Any use of information from the Interactive Channel is made at the User’s own discretion and risk, and the User bears sole responsibility for such use.
5. Intellectual Property Right
All content on the Interactive Channel is owned by or licensed to us. All images, text, videos, and other materials are protected under the Law on Intellectual Property.
Users will not copy, modify, distribute, or otherwise exploit any content without our prior written consent.
6. Links to or from the Interactive Channel
The Interactive Channel may contain links to third-party websites or platforms for the User’s reference. We do not control and shall not be responsible for the content of such websites or platforms. Accessing such links is at the User’s own discretion and risk.
The User may not link to our Interactive Channel from any other website without our prior written consent, and we reserve the right to withdraw such linking permission at any time.
7. Exemption of Liabilities
The Interactive Channel and its content are provided for reference purposes only. We do not warrant that the content is accurate, complete, or error-free.
The Interactive Channel is provided free of charge; therefore, the User uses it entirely voluntarily and assumes all risks arising therefrom. To the fullest extent permitted by law, we shall not be liable for any loss or damage whatsoever, in particular indirect losses such as loss of profits or business interruption.
III. Collect, Process and Keep Confidential of User Information
1. Data Processing Subject
All the User Information collected from the Interactive Channel will be jointly Processed and secured by MAI and its ES (acting as joint controllers) in accordance with this Privacy Policy.
That MAI and its ES Process and secure the User Information as joint controllers in each case as set forth above means that MAI and its ES will jointly decide on the purpose and measures for Processing and securing the User Information arising in each such case in accordance with this Privacy Policy and the agreement between MAI and its ES.
2. Purpose for data collection and Process
The User understands that we have legal obligations to collect, use or store your User Information in certain circumstances, including when required, consulted, recommended by legal advisors or any legal provisions, bylaws, documents or requests of the Vietnamese or foreign government or authorities, including without limitation to the obligation to disclose information and reports in accordance with the law on sales promotion, record keeping, audit, investigation and settlement of complaints or disputes, and compliance with court order or legal requirements; enforcing Terms & Conditions or other agreements; and protect our rights or property in the event of a complaint or dispute (“Purpose”).
3. User Information we collect
3.1. Information you give us:
We collect any User Information you provide us, including: (i) necessary information/arising during your accessing to and use of the Interactive Channel; (ii) through calls for customer services, advertisement and promotion, suggestions and complaints; and/or (iii) to conduct surveys, investigations, recruitment etc.
The User hereby understands and agrees that calls, messages and/or other communications from and/or to us will be stored in a form including but not limited to audio recordings, video recording, automatically or actively, to assist in processing requests, updating information systems, improving service quality and other lawful purposes.
For individual Users under the age of duly 16, please ensure that you have notified their parents or legal guardians and had the full consent and approval of parents or legal guardians to provide the User Information to the Company and the Company processes its User Information; and parents or legal guardians agree shall be bound by this Privacy Policy and are responsible for the behavior of the User under the age of duly 16 under their legal guardian. The Company reserves the right to refuse the User’s access to the Interactive Channel or provide related Services if there is evidence that the individual User whose age is under duly 16 has not obtained the above consent and approval from his/her parent or legal guardian.
In the event that the User provides the information of a third party, the User represents and warrants that the User has notified the third party of the contents under this Privacy Policy and fully obtained such third party’s consent and approval for the User to provide information to Company and for the Company to use such information, which will be subject to the terms and conditions in this Privacy Policy.
The User is responsible for ensuring that the information provided by the User is complete, accurate and up-to-date to ensure the interests of the User in accordance with the use/provide of the corresponding Service. The Company will not be held responsible in case the User provides inaccurate or incomplete information pursuant to the relevant terms of Service.
The User represents and warrants that the information that the User provides to the Company will not fall into any of the following types of information: (a) state secrets, (b) business secrets; and (c) any other information that the User is not permitted to provide in accordance with the laws or confidential agreements.
Providing User Information to us is not a requirement of law, or a contractual requirement, or a condition for entering into a contract/agreement. You are not required to provide the User Information we have requested. However, if you choose not to do so, in many cases we will not be able to respond your requests.
3.2. Automatic Information: We automatically collect certain types of information when the User interacts on the Interactive Channel.
The Company reserves the right to collect information, data related to the activities performed by the User on the Interactive Channel, including but not limited to device information (such as IP address, operating system, browser type, hardware specifications, UDIDs, MEIDs, location, address of referring website (if any), pages visited by the User from Interactive Channel and mobile applications, number of visits, responses, and other relevant information (if any)).
3.3. Collection and use of Cookies
MAI, its ES and the third parties with whom the Company partners may use automated methods, such as cookies, web beacons, advertising identifiers or other automated methods (collectively, “Cookies”) relating to the use of the Interactive Channel or other our interactive channels to identify your browser or device, learn more about customer’s preferences, provide the customer with essential features and services; and for other additional purposes. Cookies may contain unique identifiers and are stored on the User's computer or mobile device, in emails sent by the Company, on Interactive Channel, other our interactive channels and in other locations. Cookies may transmit User Information and provide/use of the Services to the Company or other entities designated by the Company. Cookies are collected for the purpose of improving User experience, by ways of the following features:
- Saving the options you have approved. This allows us to respect what you like and dislike, such as your language preferences and configuration.
- Conducting diagnosis and analysis to improve our services.
- Preventing fraud.
- Improving security.
- Measuring and analysing the quality of items on Interactive Channel.
Cookies allow you to take advantage of some of our essential features. For example, if you block or reject our Cookies, you will not be able to access certain contents or you may have to manually adjust a number of options or select the language each time you access Interactive Channel again.
You may manage your browser Cookies by adjusting the setting of your browser, blocking or deactivating Cookies, by clearing your browsing history and clearing the cache from your internet browser. You may also restrict our sharing of some of this User Information through your mobile device settings. If you disable all Cookies, neither the Company nor any third party will be able to transfer Cookies to or from your browser. However, if you do this, you may have to manually adjust some options each time you revisit the Interactive Channel and some features, channels, and services may not work.
4. How we store and protect User Information
4.1. At the Company, security is our highest priority. Our systems are designed to take into account the security and privacy of your information. All User Information is stored and kept confidential by the Company's system or service provider for the Company in accordance with the law and this Privacy Policy. Accordingly, the Company's system will store User Information arising from and/or provided by you on the Interactive Channel.
4.2. When collecting and receiving data, the Company will exert its best endeavours to the permitted extent to store and protect the User Information on the server system and these User Information will be secured by firewall systems, access control measures, data encryption. The Company has appropriate technical and security measures to prevent as much as possible to the permitted extent the unauthorized access and use of User Information. The Company also regularly cooperates with security experts to update the latest information on network security to ensure the safety of User Information. In the event our system is attacked and there is a risk that it would impact the safety and security of the User Information, the Company will comply with its obligations under the laws regarding measures to mitigate the adverse effects and notification to the User and competent authorities.
4.3. The User may not use any tools, programs or methods to illegally interfere with the system or alter the data structure on the Interactive Channel, nor any other activities to spread, promote activities with the purpose of intervening, sabotaging or infiltrating the Company system's data, as well as activities violating Vietnamese laws. In case we detect a violation, we reserve the right to transfer information about the violation to the competent authorities in accordance with the law.
4.4. We store User Information to ensure that you are able to use the Interactive Channel continuously, and store it for as long as necessary to fulfill the Purpose (as defined in Purpose for data collection and Process), or to perform other work as notified to you in advance. The period of time we retain specific User Information depends on the Purpose. When the User Information is no longer needed or the Company no longer has a business or legal purpose to retain User Information, we will treat User Information in a manner compliant with the laws regarding personal data retention.
4.5. User Information may be stored in, accessed from or transmitted to many countries, including Vietnam. When we transfer your User Information to other countries, we will ensure that such information is transferred in accordance with this Privacy Policy and is permitted under the relevant laws.
5. How we use User Information
5.1. The User hereby agrees that User Information to be collected in accordance with this Privacy Policies shall be stored and used in accordance with the consent that User give us regarding the Purpose.
5.2. It is not our policy or practice to provide User Information to any other organization or company for their or any other third party’s direct marketing or any other purpose except for the cases stipulated in this Privacy Policies.
5.3. We use your User Information only when we have appropriate legal basis to do so. Depending on each case, we may rely on your consent or on the actual situation that the processing of your User Information is necessary to perform the contract with you, or to protect your or other’s essential/material interests, or to comply with the law. We may also process the User Information when we believe that it is for our or other’s legitimate interest, taking into account your interests, rights and expectations.
5.4. For purposes of using User Information that are not mentioned above and/or that require your specific consent, we will obtain your consent to use User Information for such specific purpose when we contact you.
6. How we share User Information
6.1. User Information is an important part of our operations, and we do not sell User Information to others. We only share User Information for the Purpose in accordance with this Privacy Policy. The parties who are sharing the access to User Information must commit to strictly comply with the provisions of law and related provisions in this Privacy Policy. Accordingly, User Information may be shared to the following subjects and under the following circumstances:
- Complying at the request of the competent state authority, or as required by law;
- Providing and sharing User Information with partners at the User's request or confirmation, including but not limited via means of electronic transaction on Interactive Channel or in writing;
- Exchanging, providing and sharing User Information with its ES and partners;
- We may provide User Information to suppliers, consultants, marketing partners, research companies and other service providers, or business partners. This includes but is not limited to: server providers, information technology service providers, cloud storage providers; data analysis providers; research partners, including those conducting surveys or research projects cooperating with the Company or on behalf of the Company.
- Exchanging, providing, and sharing User Information with third parties who are the Company 's advisers, experts, agents or service providers, subcontractors: the Company may transfer User Information to advisors, experts and subcontractors to deploy the work, services suitable for the Purpose;
- Corporate transfer: In the course of business development, we may sell or buy other businesses or services. In such transactions, User Information is generally one of the transferred business assets but must still comply with the provisions of this Privacy Policy (or otherwise approved by the customer). In addition, in the event that the Company or most of the Company's assets are purchased by another company, the User Information will automatically become one of the transferred assets.
- Disclosing User Information when we believe it is appropriate to comply with the law, to enforce or apply our other terms and agreements, or to protect the rights, property or security of the Company, Users, or any other person. The above tasks may include exchanging information with other companies and organizations to prevent and detect fraud and reduce risks.
6.2. Other than the foregoing, you will receive notice when User Information may be shared with third parties and you will have the right to refuse to share information.
7. Your rights and invocation of such rights
7.1. You may view, update and delete certain information about your account and interactions on the Interactive Channel. If you cannot access or update your information yourself, you can always contact us for assistance. You can request us to implement your remaining rights in accordance with the laws by contacting us via the support channels specified in section below.
7.2. You may choose not to provide certain information, but then you may not be able to take advantage of certain functions of the Interactive Channel. Please follow the Company's instructions from time to time.
7.3. User has other rights as regulated in the prevailing Law on Data Protection.
8. Contact information, notices and modifications
8.1. This Privacy Policy may be amended and/or supplemented from time to time to be suitable for the management and operation of the Company. The Company will post the amended, supplemented and/or updated Privacy Policy on this website. You should visit and check this website regularly to update the latest changes. By continuing to access the Interactive Channel after any modification, update or modification of this Privacy Policy, the Users express its acceptance of such modification, update or modification.
8.2. If you have any questions about information security at the Company or would like to contact our information control unit, please contact us and we will try to answer the question. You can also contact us at the following email to: [email protected].
