Isuzu Vietnam Co., Ltd. (hereinafter referred to as “We” or “IVC”) respects consumers’ privacy, as well as their rights to be informed and to make choices regarding the collection and use of their information during the purchase and use of IVC’s products, goods, and services – provided by IVC or IVC’s dealers and other information related to transactions between consumers and IVC or IVC’s dealers.

This Privacy Policy (“Policy”) clearly and transparently explains how We and/or IVC’s dealer collect, store, use, modify, update, and delete (hereinafter collectively referred to as “Collection and Use”) consumer information, in compliance with Vietnam’s regulations on personal data protection, consumer rights protection, and other applicable laws.

Please read this Policy carefully and check our official website regularly for any updates or changes We may make in accordance with the terms of this Policy.

A. PERSONAL DATA PROTECTION PRINCIPLE

1. Definition and interpretation

• Personal data means any information in the forms of symbols, writing, digit, imagines, sounds or similar forms on an electronic environment associated with a specific person or helping to identify a natural person. Personal data includes basic personal data and sensitive personal data.
• Data subject means an individual to whom the personal data reflects.
• Personal data processing is one or more activities that affect personal data, such as: collection, recording, analysis, confirmation, storage, correction, disclosure, combination, access, retrieval, recover, encrypt, decrypt, copy, share, transmit, provide, transfer, delete, destroy personal data or other related actions.

2. Personal Data that IVC collect and process

Depending on the purpose of the processing of Personal data as explained below, the Personal data that We need to process on a case-by-case basis may include the following information:

a) Basic personal data

• Last name, middle nam and first name, other names (if any);
• Date of birth;
• Gender;
• Contact address.
• Personal image;
• Phone number;
• Email address;
• Other information that is associated with a specific person or that helps identify a specific person does not constitute Sensitive Personal Data;
• Information about the individual’s digital account; Personal data reflects activities, history of activities on cyberspace. Information from the electronic website or application recorded in our web or application logs, such as device information, unique identifiers (such as IP address or device identifiers), browser information (e.g. browser type, visited pages, access date/time), source of access information, data generated from the results of operations and user behavior displayed on the digital platforms. This information may also include information recorded by any cookies and recorded information about users of the website;
• Any other data about you when you use our websites, applications and/or platforms but excluding sensitive personal data.

b) Sensitive personal data

Personal location identified via location services.

3. Purpose and use range of personal data processing

3.1. We use and process the personal data we collect to the extent necessary and legitimate and for the following purposes:

Provision of products, services

• To manage IVC’s relationship with customer.
• To communicate with or advise Dealers of IVC, customers, IVC’s partners, any party who may enter into contractual relations with IVC via email, telephone, post, or in person in relation to IVC’s products, services, events and other information such as research and analysis newsletters that may be of interest to the customer.

Customer care

• To ensure customer satisfaction and provide professional customer support.
• To respond to inquiries, process the customer’s requests and complaints, keep records of interactions, comments and/or complaints.

Business operation of IVC

• To identify issues with products and services.
• To carry out and improve business activities, business performance.
• To plan the improvements to the products and services.
• To do reports, statistics, market research, analytic report.
• To serve the management and administration activities of IVC.
• Recruiting employees.
• Personnel and administrative management: implementation of labor contracts in accordance with the provisions of law, organizing the implementation of policies/ processes to maintain and develop the capacity/ motivation of employees, adapt the operational demand of IVC.

Marketing

• To develop and carry out any marketing activities, transfer the information to customers through online and offline forms/tools (such as email, phone, post office, digital and social networking platform, etc.) about IVC’s products, services that the customer may be interested in.

To submit regulatory reports to relevant authorities.

3.2. Means of processing: IVC may perform Personal Data Processing manually or electronically for one or more activities affecting personal data, such as: collection, recording, analysis, confirmation, storage, rectification, disclosure, combination, access, traceability, retrieval, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction or other relevant activities.

4. Organizations, individuals permitted to process personal data or involve the personal data processing for aforesaid purpose

Besides IVC, personal data provided can be processed by the following organizations, individuals:

• IVC’s Affiliates including a party is directly or indirectly involved in the management, control of, contribution of capital to, or investment in, IVC; parties that together with IVC are managed (directly or indirectly), controlled, capitalized, or invested by another third party. E.g. Parent company, members of IVC, etc.
• IVC’s Dealers, IVC’s partners, any party who may enter into contractual relations with IVC regarding the products or services of IVC, and vendors who provide goods, services for IVC (provided that such party has entered into a confidentiality undertaking with IVC, except that there shall be no requirement for a confidentiality undertaking if the recipient is a professional advisor such as financial advisor, auditors and lawyers, and is subject to professional obligations to maintain the confidentiality of the information);
• To any party that IVC has been instructed by the data subjects to share the personal data with.
• To relevant authorities as required by laws.
• Personal data may be transferred abroad for Processing. The Parties involved in the Processing personal data are obligated to protect the personal data in accordance with appropriate safeguards.

5. Rights and obligations of the Data subject

The Data subject’s rights: The right to be informed, the right to give consent, the right to access, rectify or request rectify my personal data; the right to revoke my consent; the right to erase or request to erase my personal data; the right to request restriction of processing of my personal data; the right to request provision of my personal data; the right to object the processing of my personal data; the right to file complaints, denunciations and lawsuits; the right to claim damage and the right to self-protect in accordance with laws.

The Data subject’s obligations: The obligation to protect my own personal data and request relevant organizations and individuals to protect my personal data; respect and protect others’ personal data; fully and accurately provide my personal data when I consent to the processing of my personal data; participate in dissemination of personal data protection skill; comply with regulations of law on protection of personal data and prevent violations against regulations on protection of personal data.

6. Measures to protect personal data and undesirable consequences and damage that may occur

IVC is committed to keeping personal data confidential by any means possible. IVC will use many information security technologies as recommended by state agencies to protect personal data from unauthorized attacks. However, due to technical limitations, no data can be 100% secure when transmitted on the internet. Therefore, IVC cannot make a firm commitment that the personal data that Data Subject provides to us will be kept absolutely secure, and we cannot be responsible in the event of unauthorized access to the personal data of the Data Subject such as the cases in which the Data Subject voluntarily shares data with others.

7. Personal data processing time: The processing of my personal data can be started at the time IVC receives the personal data and will end as soon as all the above processing purposes have been fulfilled.

8. Select, access and change your personal data

• You may review, update, modify or delete any information you have submitted on our website, application and/or any other social networkings by logging into your account or contacting us with the information specified at Part E of this Policy. However, if you request to delete your personal information, please note that we may still retain some data in the following cases:
• The deletion of personal data is prohibited by law;
• The personal data is processed by the competent state agency to serve operations by such agency as prescribed by law;
• The personal data has been disclosed as prescribed by law;
• The personal data is processed with a view to serving law, scientific research and statistics as prescribed by law;
• The personal data shall not be deleted in the event of a state of emergency on national defense, security, social order and safety, major disasters, or dangerous epidemics; when there is a risk of threatening security and national defense but not to the extent of declaring a state of emergency; to prevent and combat riots and terrorism, to prevent and combat crimes and law violations according to regulations of law;
• It is required to respond to emergent cases that threaten the life and health or the safety of the data subject or other persons.

B. CONSUMER INFORMATION PROTECTION PRINCIPLE (FOR NON-PERSONAL DATA)

1. Consumer Information includes information of Consumer about the process of purchasing and using IVC’s products, goods and services – provided by IVC or IVC’s dealers, and other information related to transactions between Consumers and IVC or IVC’s dealer network.

2. Purposes of collection (“Purposes”) and scope of use of Consumer Information

2.1. Provision of products, services:

• To manage IVC’s relationship with consumer;
• To communicate with or advise dealers, consumers, partners of IVC, any party who may enter into contractual relations with IVC via email, telephone, post, or directly in relation to IVC’s products, services and other information such as research and analysis newsletters that may be of interest to the consumers.

2. 2. Customer care:

• To ensure consumer satisfaction and provide professional customer support;
• To respond to inquiries, process the consumer’s requests and complaints, keep records of interactions, comments and/or complaints.

2.3. Business operation of IVC:

• To identify issues with products and services;
• To carry out and improve business activities, business performance;
• To plan the improvements to the products and services;
• To do reports, statistics, market research, analytic report.

2.4. Marketing: To develop and carry out any marketing activities, transfer the information to consumers through online and offline forms/tools (such as email, phone, post office, digital and social networking platform, etc.) about IVC’s products, services that the consumer may be interested in.

2.5. To submit regulatory reports to relevant authorities;

2.6. To submit a post-training report to consumers’ management company.

3. Consumer Information Storage Duration: Beginning at the time the consumer agrees to provide their information and ends immediately after the Purposes have been fulfilled.

4. Parties that may access and use Consumer Information

Consumer Information is collected, stored, used, modified, updated, and deleted by IVC or IVC’s dealers. IVC does not share such information with any third party for their own purposes without the consumer’s permission. IVC only shares Consumer Information with the following parties for the purposes stated in this Policy:

4.1. IVC’s Affiliates include parties that are directly or indirectly involved in the management, control of, capital contribution to, or investment in IVC; parties that together with IVC are managed (directly or indirectly), controlled, capitalized, or invested by another third party. E.g. Parent company, members of IVC, etc.;

4.2. IVC’s dealers, IVC’s partners, any party entering into contractual relations with IVC regarding the products or services of IVC, and vendors who provide goods, services to IVC (provided that such party has entered into a confidentiality undertaking with IVC, except that there shall be no requirement for a confidentiality undertaking if the recipient is a professional advisor such as financial advisor, auditors and lawyers, and is subject to professional obligations to maintain the confidentiality of the information);

4.3. Any party as instructed by the consumer for IVC to share the information with;

4.4. Relevant authorities as required by laws.

5. Rights and obligations of the consumer

5.1. Rights of the consumer

a) The right to permit or not permit the performance of the following acts:

• Sharing, disclosing, or transferring information to third parties, except in cases where IVC transfers information that has been lawfully collected in accordance with the regulations on consumer right protection and other applicable laws to third parties for the purposes of storage or analysis in support of IVC’s business operations, provided that IVC and such third party have entered into a written agreement on the responsibility to protect Consumer Information in accordance with applicable laws;
• Using Consumer Information for the purposes of advertising, marketing products, goods, or services, and carrying out other commercial activities.

b) Other rights as prescribed by laws.

5.2. Obligations of the consumer

The obligation to protect one’s own information and request relevant organizations and individuals to protect such information; to respect and protect the information of other organizations and individuals; to fully and accurately provide information when consenting to its collection and use; to comply with the provisions of law on the protection of Consumer Information; and to participate in the prevention of violations against legal regulations.

6. Measures to protect and ensure the security of Consumer Information; Undesirable consequences and potential damages that may arise

IVC is committed to keeping information confidential by all possible means. IVC will adopt various information security technologies as recommended by state authorities to protect the information from unauthorized attacks. However, due to technical limitations, no data transmitted over the internet can be guaranteed to be 100% secure. Therefore, IVC cannot make any firm commitment that the information provided by consumers will be kept completely secure, and we shall not be liable in cases of unauthorized access to such information, including but not limited to situations where consumers voluntarily share their information with others.

C. PROTECTION OF THE RIGHTS OF VULNERABLE CONSUMERS

1. Vulnerable consumers are those who are likely to be subject to significant disadvantages in terms of access to information, health, property, and dispute resolution at the time of purchasing or using products, goods, and services, including:

• Elderly persons as defined by the laws on the elderly;
• Persons with disabilities as defined by the laws on persons with disabilities;
• Children as defined by the laws on children;
• Ethnic minorities; persons living in ethnic minority and mountainous areas, islands, areas with difficult socio-economic conditions, or extremely difficult socio-economic conditions as defined by law;
• Women who are pregnant or raising a child under 36 months of age;
• Persons suffering from critical illnesses as defined by law;
• Members of poor households as defined by law.

2. The protection of vulnerable consumer rights shall be implemented as follows:

• Vulnerable consumers are guaranteed the rights of consumers in accordance with the provisions of this Policy, the Consumer Right Protection Law and priority rights and policies in accordance with other relevant laws;
• When a vulnerable consumer submits a request for protection along with evidence and documentation proving their status as a vulnerable consumer and that their rights have been infringed, IVC and/or the dealers will give priority to receiving and handling the request, and will not forward it to a third party for resolution, unless such third party has relevant obligations. In case of refusal to handle the request, IVC and/or the dealers must provide a written response, clearly stating the legal basis and the inconsistency with the published policy as prescribed in Section 3, Part C of this Policy;
• IVC and/or the dealers must compensate vulnerable consumers for damages in accordance with the provisions of civil law in case of any delay in, refusal to prioritize, or refusal to receive and handle requests as prescribed at Section 2.b, Part C of this Policy;

3. When transacting with vulnerable consumers, IVC and/or the Dealers shall have the following responsibilities:

• Ensure the exercise of the rights of vulnerable consumers in the purchase and sale of products, goods and the provision of services in accordance with laws;
• Ensure the right to file complaints, request dispute resolution, and exercise other rights of vulnerable consumers;
• Apply processes, procedures, and methods of receiving and resolving complaints in a flexible manner, appropriate to each vulnerable consumer, based on their circumstances, access to information, ability to exercise rights, etc. This may include providing documents in easy-to-understand language, offering reading and writing support for the visually impaired, giving instructions in ethnic minority languages when necessary, or assigning staff to provide counseling and assistance to those who face difficulties in accessing information;
• Do not refuse to handle protection requests from vulnerable consumers, as specified in Section 2.b, Part C of this Policy, on the grounds of differences in language, script, customs, or cultural practices;
• Prevent discrimination, unequal treatment, or exploitation of vulnerabilities to infringe upon the lawful rights and interests of consumers during transactions;
• Fulfill other responsibilities in accordance with the law on consumer right protection and other relevant legal regulations.

4. Methods of receiving complaints:

Directly at the IVC’s dealers;

By phone: (84-8)3 895 9203 or email info@isuzu-vietnam.com;

Working time: From 8.00 a.m. to 5.00 p.m. every Monday – Friday, except Saturdays, Sundays and public holidays and Tet as prescribed by laws.

5. Complaint handling procedures and measures:

a) Receipt and verification:

• Review documentation and evidence proving that the consumer belongs to a vulnerable group;
• Verify the content of the complaint and supporting evidence of violations or infringements of rights.

b) Complaint resolution:

• Proactively clarify the cause and responsibility, and coordinate with relevant parties for resolution;
• Assist consumers in exercising their right to file complaints, request compensation, and remedy consequences;
• Prioritize methods that are convenient and minimize costs or complexity for the consumer.

c) Response to results:

• Inform the consumer of the outcome through a method appropriate to their level of access.

D. CHANGES TO THIS POLICY

This Policy may be updated from time to time, and any updated version will be posted on IVC’s website at https://isuzu-vietnam.com. The consumers are encouraged to visit the website regularly to check for any modifications.

E. CONTACT IVC

If you have any questions, requests or concerns regarding this Policy or if you wish to exercise your rights as a consumer, please contact us at the relevant address below.

ISUZU Vietnam Co., Ltd

Address: 695 Quang Trung, Thong Tay Hoi Ward, Ho Chi Minh City, Vietnam

Phone number: (84-8)3 895 9203

Email: info@isuzu-vietnam.com