CONSUMER PERSONAL INFORMATION PROTECTION POLICY

·        I. General Principles

This Privacy and Information Sharing Policy (“Privacy Policy”) describes how DTrack Technology and Service Co., Ltd. (hereinafter referred to as “DTrack” or “We”) collects, receives, aggregates, stores, uses, processes, discloses, shares, and secures the information of organizations and individuals (“Customers”) who access and use the website provided by DTrack – myfarm.asia (“MYFARM”) and/or use other goods, services, and interaction channels provided by DTrack. Please read this Privacy Policy, the corresponding terms and conditions, and other applicable regulations carefully.

Customers herein are defined as individuals who log in and use the goods and services purchasing features on the website myfarm.asia.

This Privacy Policy does not apply to any products, services, websites, applications, or content provided by third parties outside the scope of the MYFARM services mentioned above, or third parties that maintain their own independent privacy policies.

“Customer Information” under this Policy refers to the Customer's personal information and all other data related to the Customer that We receive, collect, process, use, store, and share during the Customer's access and use of MYFARM services. Among these, personal information is crucial and mandatory data required to identify an individual or organization, specifically including:

·        Display name

·        Full legal name

·        Email address

·        Phone number

·        Gender

·        Date of birth

·        Address

·        Personal image/Avatar

·        II. Information Collection

1. Purpose of Information Collection

We use your Customer Information to operate, provide, and improve MYFARM services for our specific purposes (“Usage Purposes”), including:

(a) Providing, personalizing, maintaining, and improving products and services:

·        Providing MYFARM services to Customers; introducing new goods, products, and services from Us or our partners based on Customer needs and habits during the use of MYFARM services.

·        Creating, managing, and updating Customer accounts; verifying Customer identity.

·        Managing, operating, providing, and administering Customer activities while using MYFARM services.

·        Confirming transactions, sending transaction notifications, and processing payments authorized by the Customer.

·        Checking creditworthiness, verifying information accuracy, and authenticating data with third parties.

·        Processing and managing rewards, prizes, or incentives related to MYFARM services.

·        Enabling interactions between Customers, and between Customers and Us.

(b) Ensuring safety and security for MYFARM services and all Customers during use.

(c) Support and service improvement: Communicating with and supporting Customers, and handling valid Customer requests.

(d) Marketing and promotion: * Sending notifications, updates, advertisements, promotions, greetings, invitations, and materials related to the Services, Us, our sponsors, partners, and advertisers via methods compliant with the law.

·        Customers may opt-out of receiving marketing and promotional information by following our instructions provided from time to time.

(e) Legal obligations: We have a legal obligation to collect, use, or store Customer Information in certain cases, including when required, advised, or requested by competent state authorities.

(f) Anti-fraud and risk management: Detecting and preventing fraudulent activities, account sabotage, or identity theft during the use of MYFARM services.

(g) Other lawful purposes consistent with the objectives of MYFARM services.

2. Methods and Scope of Information Collection

We collect Customer information through the following methods:

·        Information provided directly by Customers: Via account registration forms and updates during the use of MYFARM services.

·        Direct communication: Through interactions, feedback, surveys, opinions, exchanges, agreements, and dispute resolutions between Customers and Us.

·        Third-party information: If a Customer provides information regarding a third party, the Customer represents and warrants that they have obtained full consent and approval from said third party for the disclosure of their information to Us and for our use of that information in accordance with this Privacy Policy.

·        Information from other sources: We may collect Customer information from partners, referral programs, surveys, promotions, or publicly available sources in compliance with applicable laws.

3. Other Usage Purposes

For any usage purposes not mentioned above and/or requiring specific consent, We will seek the Customer's approval for that specific use when contacting them.

4. Scope of Customer Information Use

Customers hereby agree that Information collected under this Privacy Policy will be provided and used according to the Customer's consent for the Usage Purposes stated above.

5. Authorized Access to Information

We commit not to provide Customer personal information to any third party for any purpose other than those stated in Section II:

·        Internal departments (Technical, Sales, Order Control, and other authorized staff).

·        Subsidiaries, affiliates, and other related entities within our corporate group for the purpose of providing MYFARM services.

·        Delivery partners, telecommunications, internet messaging providers, and other strategic partners.

·        Third parties as requested or confirmed by the Customer.

·        Competent state authorities as required by law.

6. Security and Storage

We store and secure Customer personal information on system servers, protected by a backup system using snapshots provided by AWS.

We retain Customer Information to ensure continuous access to MYFARM services, for the duration necessary to fulfill the Usage Purposes, for legal compliance (including tax and accounting purposes), or for other tasks as previously notified to the Customer.

7. Information Retention Period

Information is stored by Us until the Customer withdraws their consent in accordance with Section 11 of this Policy.

8. Customer Obligations and Responsibilities

·        Accuracy of Information: Customers must provide and update their personal information truthfully and accurately. Customers commit to ensuring the accuracy and completeness of the provided information and must promptly update it if any changes occur. We are not responsible for resolving any disputes or complaints if the information provided is inaccurate, incorrect, or fraudulent.

·        Communication Channels: Unless otherwise notified by the Customer, We will continue to provide MYFARM services and/or contact the Customer via the registered addresses. All communications sent to the latest contact information registered with Us will be deemed delivered, regardless of actual receipt.

·        Service Suspension: If communication is returned due to incorrect, unupdated, or invalid contact information provided by the Customer, We will suspend MYFARM services, and the Customer will be unable to perform any transactions until valid updates are received.

·        System Integrity: Customers are strictly prohibited from using any tools, programs, or measures to unlawfully interfere with the system or alter the data structure of any MYFARM services. Any actions aimed at distributing, encouraging, or executing hacking, destruction, or intrusion into Our system data, or any other acts violating Vietnamese law, are strictly forbidden. In case of violations, We reserve the right to transfer violation details to competent state authorities for legal processing.

·        Agreement to Updates: By using MYFARM services, Customers acknowledge they have read, understood, and agreed to this Privacy Policy. We reserve the full right to amend, supplement, and/or update this Policy at any time. Changes will be posted on the MYFARM website at least 05 days before they take effect. Continued use of services after such updates constitutes agreement to the revised Policy.

9. Entity Information and Contact Details

DTRACK TECHNOLOGY AND SERVICE CO., LTD

·        Address: 1st Floor, International Plaza, No. 343 Pham Ngu Lao, Ben Thanh Ward, District 1, Ho Chi Minh City, Vietnam.

·        Business Registration No.: 0317537788 (Issued by the HCMC Department of Planning and Investment on October 26, 2022).

·        Contact Information:

o   Email: nhut.le@demeter.vn

o   Phone: 0903 344 277

10. Access and Correction of Personal Data

Customers can view, update, or delete certain account information and interactions via:

·        Self-service: Accessing the "Edit Profile" section (top right corner of the screen).

·        Support: Contacting Us via the information provided in Section 9 above.

·        Data Choices: Choosing not to provide certain information may limit access to specific MYFARM services. When information is updated or deleted, We typically retain a copy of the previous version for records.

·        Marketing Opt-out: Customers may unsubscribe from promotional messages by following the instructions provided in our communications.

11. Methods to Withdraw Consent

·        To withdraw consent for data collection and processing, Customers may contact the hotline at 0903 344 277 or email nhut.le@demeter.vn.

·        Withdrawal of consent does not affect the legality of any data processing performed prior to the withdrawal.

·        Consequences: Withdrawing consent means We can no longer provide MYFARM services, which may lead to the termination of the relationship or contract. We shall not be liable for any losses incurred by the Customer due to such termination.

12. Complaint Resolution Mechanism

When does the mechanism operate? At any time. If you suspect your personal data has been misused or used outside the declared scope, you may submit inquiries or complaints via:

·        Phone: 0903 344 277

·        Email: nhut.le@demeter.vn

·        Fanpage: https://www.facebook.com/myfarm.trongcaynuoicon

Process:

1.     Receipt: Complaints are handled by the Customer Service and System Security departments.

2.     Analysis: A multidisciplinary team analyzes the root cause and formulates a solution.

3.     Resolution: We will respond immediately or within a maximum of 24 working hours (excluding Sundays) with an explanation, apology, or compensation plan (if applicable).

4.     Reporting: All records are updated with preventative measures and reported to the General Director.

13. Validity

This Privacy Agreement is effective from June 27, 2024. We reserve the right to modify this agreement by notifying Customers via the MYFARM website. Revised terms become effective as of the date specified in the modification decision. Continued use of MYFARM services signifies acceptance of the revised terms.

In the event that any provision of this Agreement conflicts with Vietnamese law and is declared void by a court, such provision shall be adjusted to comply with current law, while the remaining provisions shall remain in full force and effect.