Notice on personal data processing activities

PRIVACY POLICY

GS BATTERY VIETNAM CO.,LTD

Last updated July 1, 2023

By accepting this Privacy Policy ("Policy"), you agree to allow GSV to use your personal data for the purposes and methods stated herein. In case you do not agree or have any other comments regarding the purpose of processing personal data or other details of the Policy, please inform GSV at the Contact section.

GS Battery Vietnam Co., Ltd. respects and protects your privacy.

GS Battery Vietnam Co., Ltd. ("GSV", "we", "us") is committed to protecting and respecting your privacy. This Privacy Policy provides you with information on how GSV processes your personal data including but not limited to when: (i) you visit a distributor; you access, use and provide information through GSV websites; you download and use applications, use sensor devices; you contact us or use goods, services provided by GSV or participate in other programs or events organized by us (such as from contests, games, promotions, events, fairs and exhibitions, charity programs, community or social activities organized or participated by us, from your interactions with us (for example through social networks, answering survey questions, registering to attend events and/or receiving prizes...), (collectively "Interactions"), and (ii) we collect from other third parties. This Policy also sets out your rights regarding personal data protection. More specific information about your rights is set out in the section Your Choices and Rights.

We may also provide you with additional information during the course of collecting your personal data, and where we consider it appropriate and timely to provide the information.

Data we collect and process

Personal Data is information that is associated with or helps to identify a specific individual ("Personal Data"). Depending on the source of collection, the Personal Data we collect may include, but is not limited to, the following information:

Basic personal data:

• Contact information or personal identification information: such as full name, date of birth, gender, height, weight, occupation (including position, place of work), education level, employer, nationality, marital status, permanent residence, temporary residence, current residence, hometown, contact address, personal image, telephone, emergency contact information, email, passport, citizen identification card (or other personal identification number including, but not limited to, information on date of issue, place of issue and issuing authority), personal tax code number, social insurance number, health insurance card number, social network account, and driver's license
• Personal data reflects activities and history of activities in cyberspace
• Information to create a user profile: such as username, password, PIN or security question and answer;
• Product information: product name code, product manufacturing date, product lot number, barcode, product QR code;
• Social Media Widgets: Our websites and mobile applications include social media features that are linked to social media platforms such as Facebook, Twitter, Instagram, Snapchat, Google Plus, Pinterest, YouTube, and others. These features may collect information about your IP address and the pages you visit on our websites, and these platforms may set cookies or use other tracking technologies. Social media features and widgets may be hosted by a third party or hosted directly on our websites. Your interactions with these features are governed by the privacy policies of the companies providing the features;
• Any other Personal Data that you enter or decide to provide to us when you Interact with GSV including but not limited to your family status, interests, behavior, questions, complaints, opinions, signature, photos, videos and location.

Sensitive personal data:

• Information regarding racial origin, ethnic origin
• Information about the individual's physical attributes and biological characteristics
• Financial information: such as your bank account number, account name, bank name and billing address, income, vehicle financing, other financial information;
• Payment information: Credit card, payment method (Cash/Bank transfer/Installment).
• Location Information. We receive location information from the devices you use to connect to the GSV website(s) or you use to store or access the GSV application. Location information may be obtained through the use of geolocation features in your devices or sensors or through other means such as using your IP address to determine your general geographic area;

Source of Personal Data Collection

We may collect and process any Personal Data when you Interact with us. It is your responsibility to ensure that the data you provide is complete, accurate and always updated to ensure your rights under the provisions of the respective service use. We are not responsible in case you provide inaccurate, outdated, or incomplete data.

In the event that you provide us with Personal Data of a third party, you represent and warrant that you have and have obtained the full consent and approval of that third party for you to provide their Personal Data to GSV and for GSV to use such Personal Data in the manner and as set out in this Privacy Policy.

You also warrant and undertake that the information you provide to GSV will not be any of the following types of information: (i) state secrets, (ii) business secrets; and (iii) any other information that you are not permitted to provide under the provisions of law or confidentiality agreements.

We may collect your Personal Data from other sources, including but not limited to service providers (such as insurance, installment, credit...), partners, referral programs, publicly available sources; and/or when another user provides your Personal Data to us with your authorization and/or consent in surveys, investigations, promotions, community charity programs, information documents, etc. When we collect your Personal Data from other sources, we ensure that such Personal Data is transferred to us in accordance with the provisions of applicable laws.

Information We Collect Automatically

We also collect information and data in the form of (1) cameras that automatically record images when you attend our company or events that we participate in organizing….(2) that do not allow identification of a specific individual. We may collect, use, transfer, and disclose information that is not Personal Data for any purpose.

For example, we may collect information from the devices (computers, tablets, smartphones, etc.) that you use to connect to the GSV website(s) or that you use to host or access the GSV application. The information we receive from these devices may include the device serial number, device identifiers, device MAC address, browser type, Internet service provider, hardware version, operating system, connection information, and application version. When you use and/or interact with the GSV website(s) or application, we may also record certain information and store it in log files. This information may include the source and last accessed pages, date and time stamps, search terms, and data about the sequence of pages visited;

If we aggregate non-Personal Data with your Personal Data, the aggregated information will be treated and used by us as Personal Data.

Manner and Purpose of Data Processing

We may process your Personal Data by automated or manual means, within the scope and for the purposes set out in this Policy.

The Legal Bases what we collect, use, store, share and process personal data

1. Your Agreement ("Agreement ");
2. Necessary for the performance of a contract with you ("Contract");
3. The purpose of protecting your life or health or that of others in an emergency ("Life & Health");
4. The use of your personal image from public activities without harming your honor, dignity, reputation ("Public Image");
5. Obligation to comply with the provisions of law ("Compliance").

We may collect, use, store, share and process your Personal Data for the purposes and based on the legal bases set out below:

1. Provide GSV websites or GSV applications and related products and services to you, including but not limited to:
• To evaluate and improve our services, for example to develop new products or services and improve, manage work systems;
• Create, manage and update user accounts, verify user identity;
• Manage, operate, provide and/or administer your use and activities when you Interact with us;
• Access information stored on your device to understand your preferences and improve your customer experience, for example, by providing you with customized content and offers that match your personal preferences;
• Perform any contract that GSV or other relevant parties have with you (for example, to facilitate online payments and provide products and services);
• Allow us to understand your interests and preferences so that GSV websites or GSV applications can be tailored to your needs;
• Respond to your requests, such as sending you promotional materials, locating the nearest GSV distributor, or arranging a service for you related to GSV products; assisting you in purchasing a vehicle or using a service provided by GSV or a distributor; assisting you in participating in or receiving rewards, prizes at promotions, events, programs, competitions organized by GSV or a distributor;
• Notify GSV distributors and affiliates of any services, or other appointments related to you or your GSV products; and respond to questions and complaints from users.

Legal basis: Contract, Agreement.

2. Measure, support, maintain and improve GSV websites, applications and related products and services, including but not limited to:
• Manage GSV website resources or GSV applications;
• Improve and optimize GSV websites or GSV applications and GSV products and services;
• Investigate and identify issues of concern;
• Monitor and improve the response from GSV customer support;
• Communicate steps taken to resolve customer support issues;
• Ask you to provide feedback or participate in surveys (which may be conducted by us or a third party) about our vehicles, products, services and distributors; and
• Measure usage, analyze performance, find ways to improve and develop websites, applications, products and services.

Legal Basis: Agreement.

3. Research and development, including but not limited to:
• Manage GSV website resources or GSV applications;

Legal Basis: Agreement.

4. Contact you for the above purposes (directly by GSV or through a GS Yuasa Group company, an authorized GSV distributor, a related partner or distributor) by post, telephone, e-mail, text message or automated notification.

Legal basis: Contract, Agreement.

5. Internal storage. Management, backup for disaster recovery or other similar purposes.

Legal basis: Contract, Compliance.

6. GSV may also convert Personal Data into anonymized data or receive data from third parties in a non-customer-identifiable form on a lawful contractual basis and use such data (usually on an aggregated basis), for example for market research and analysis, to improve GSV's products and services, to analyze trends and evaluate the success of advertising campaigns.

Data analytics techniques are used to study your online activity and purchase history so that you have a more seamless experience when interacting with GSV online and offline.
Anonymized information will no longer be considered Personal Data for the purposes of this Privacy Policy.

7. Marketing and advertising, including but not limited to:
• Provide you, including but not limited to, promotional/marketing information, product and service introductions, commercial information and other information, or offers, proposals, and offers related to products and services of GS Vietnam Battery Company Limited that may be of interest to you via post, telephone, text message, e-mail, social networks (such as Facebook), online forums, blogs, automatic notifications and other methods or platforms (such as electronic methods, online methods).
• Where you have consented to receive advertising/marketing, you will always have the opportunity to withdraw your consent and unsubscribe from our newsletters by following our instructions from time to time.

Legal Basis: Agreement.

8. Where necessary to comply with a legal obligation, including but not limited to:

We have a legal obligation to collect, use or retain your Personal Data in certain circumstances, including but not limited to: When requested, advised, recommended or required by our legal advisors or any law, regulation, regulation or request from any government or other competent authority, local or foreign; When performing obligations under law, including disclosure obligations, promotional reporting, record keeping, auditing, investigation, complaint or dispute resolution, and other obligations; Complying with court orders or legal requirements; Enforcing terms, conditions or other agreements; And protecting our rights or property in the event of a claim or dispute.

Legal Basis: Compliance, Agreement.

9. To prevent and investigate fraud, illegal acts, evasion of obligations or wrongful acts which may or may not be caused by or related to the provision of services by GS Battery Vietnam Co., Ltd.
   Legal Basis: Compliance, Agreement.
10. To protect customers, employees and other individuals as well as protect data, confidentiality and assets of and entrusted to GS Battery Vietnam Co., Ltd. and our affiliates, and to protect the security of the systems and facilities of GS Battery Vietnam Co., Ltd. and our affiliates.
    Legal Basis: Life and Health, Compliance, Contract, Consent.
11. When necessary to protect the legitimate interests and legal rights of GSV, including but not limited to:
    Use information for reasons related to compliance, regulatory requirements, audits and claims (including disclosure in connection with legal or litigation proceedings) and other ethics and compliance reporting requirements.
    Legal Basis: Compliance, Agreement.

Where not contrary to applicable law, we may collect, use and store your Personal Data for other purposes that we desire or deem necessary or appropriate..

How We Share Your Personal Data

We may share your personal data with the following parties for any or all of the purposes set out in the How and For What Purposes of Data Processing section above..

1. Provision of Personal Data between Companies within the GS Yuasa Group
   We may share your Personal Data with members of the GS Yuasa group and our holding companies. For this purpose, your Personal Data may be transferred to, processed in, or accessed from a country outside Vietnam (e.g. Japan).
2. Providing Personal Data to GSV distributors and authorized repairers
   We may share your Personal Data with GSV distributors and authorized repairers in Vietnam. For example, if you make an online request to schedule a vehicle experience or service related to a product, we will ask your local GSV distributor to contact you to arrange for a vehicle experience or service at a suitable time.
3. Providing Personal Data to companies providing contracted services
   We may provide Personal Data to GSV's suppliers, consultants, marketing partners, research firms and other service providers or business partners, including but not limited to: payment processing and support partners; anti-money laundering services; hosting providers, information technology services, cloud computing service providers; advertising partners and advertising platform providers; data analytics providers; research partners, including those conducting surveys or research projects in partnership with GSV or on behalf of GSV; insurance and financial partners. Your Personal Data may also be shared with third parties who are consultants, consultants, agents or service providers, subcontractors of companies within the GS Yuasa Group.
4. Providing Personal Data to other organizations or other parties

We may provide Personal Data to the user(s) and other owner(s) (whether present or future) of your GS branded battery, warranty information, service history and other information (if any) relating to that GS branded product if we deem this necessary to facilitate the use of the GS branded product and/or GS Battery Vietnam Co., Ltd. applications (apps).

We may provide information to third parties if we are under a duty to disclose your Personal Information to comply with a legal obligation or if we believe it is necessary for us to protect the rights, property or safety of GSV, our customers or others. This may include exchanging information with other companies and organizations to prevent and detect fraud and reduce risk.

We may provide information to government agencies and/or law enforcement if required by law or where necessary to protect our legitimate interests in accordance with applicable law.

We may provide information to potential or actual purchasers in the event that GSV, or any part of the GS Yuasa group, sells any of its business or assets including your personal data. We may also retain a copy of this information.

We may provide information to relevant party(ies) in the event of a bankruptcy, merger, acquisition, or restructuring involving GSV, and your Personal Data/information may be sold or transferred as part of that transaction. We may also retain a copy of this information.

Your Choices and Your Rights and Obligations

1. Your rights as a data subject

In addition to the right to consent, to be informed about the processing of Personal Data, and to exercise the rights of self-defense as prescribed by civil law, you have the right to exercise it yourself by logging into your account or requesting GSV according to the contact information in the Contact Us section below to:

• View, correct or request correction of your Personal Data;
• Withdraw your consent to the processing of your Personal Data (where Personal Data is processed on the basis of consent);
• Restrict the processing of your Personal Data;
• Provide your Personal Data to yourself;
• Object to the processing of your Personal Data to prevent or restrict the disclosure of your Personal Data or its use for advertising or marketing purposes; and
• Delete your Personal Data.

These rights may be limited, for example, if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information that we are required to retain by law or have legitimate interests to retain, or your request is limited by law.

2. Your obligations

In addition to the above rights, you, as a data subject, also have obligations under the law such as respecting and protecting the Personal Data of others and providing complete and accurate Personal Data when consenting to the processing of Personal Data..

GSV will not be liable for your violations of the applicable laws on the protection of Personal Data as well as this Policy. You agree to indemnify and hold GSV harmless and not responsible for any and all of your non-compliance with the applicable laws on the protection of Personal Data as well as this Policy (including but not limited to not impersonating another individual when providing Personal Data to us, and only providing another person's Personal Data to us with the consent of the data subject)

3. Give your rating and share your thoughts

When using our websites or mobile applications, you may share information via social networks such as Facebook and Twitter. For example, you may ‘like’, ‘share’ or leave a review of our services. When you do this, your Personal Data may be displayed to the providers of those social networks and/or their other users. GSV is not responsible for your privacy when you use your social network accounts. It is your responsibility to set appropriate privacy settings on your social network accounts to manage how your information is used and shared on those social networks.

Advertising and Marketing

We will seek your consent to use your Personal Data for advertising and marketing purposes. If you do not want us to send you advertising/marketing information, or use your Personal Data for profiling in connection with advertising/marketing, or send your Personal Data to third parties for advertising/marketing purposes, you can ask us not to do this, at any time, by:

• Responding to a promotional/marketing email by clicking the ‘unsubscribe’ button;
• By changing the privacy settings within an application (if available on the application);
• By following the opt-out or unsubscribe instructions set out in our relevant communications;
• Otherwise as directed by us from time to time.

Data Storage and Protection, Retention Period

1. Data Storage and Protection

We will take your Personal Data seriously. We have reasonable technical and physical safeguards in place to protect the Personal Data we collect. However, please note that although we take reasonable steps to protect your Personal Data, no safeguard is 100% secure and we cannot guarantee the security of your Personal Data, for example against unauthorized access and use of Personal Data by hackers.

Some of our key safeguards are: (a) we limit access to your Personal Data on a “need to know” basis and only for the stated purpose; (b) we monitor access to our information technology systems to detect and prevent misuse of Personal Data; (c) we use technology controls over our information systems, such as firewalls, user verification, data encryption, and segregation of roles, systems & data.

If you have a personal password that enables you to access certain parts of our websites or any other portal, application or service we operate/manage, you are responsible for keeping this password confidential. We ask that you do not share your password with anyone else.

2. Storage Time

We will only retain your Personal Data for as long as we need it to fulfil the purposes for which we process Personal Data as set out in this Policy, unless otherwise required by Vietnamese law. At the end of the retention period or as we deem appropriate, we may, in our sole discretion and in accordance with the law, take steps to destroy your Personal Data or store it in anonymised form unless otherwise required by Vietnamese law.

Links to third party websites or applications

Our website or application may, from time to time, contain links to or from the websites of our partner networks, advertisers and group companies. GSV is not responsible for the content of any websites linked to the GSV website or application. When accessing a third party website or downloading a third party application, it is your responsibility to ensure that you have read the privacy notice and legal terms and conditions applicable to that website or application.

Updates to this Policy

This Policy may be updated periodically. Accordingly, we will update the date at the top of this Policy and encourage you to check for changes to this Policy posted on the GSV website. In some cases, we may also proactively notify you of specific data processing activities or material changes to this Policy and seek your consent to such changes, where required by applicable law.

Contact us

If you have any questions or concerns about this Policy, please contact us at:

GS Battery Vietnam Co., Ltd.

Address: No. 18, Road No. 3, Vietnam - Singapore Industrial Park, Binh Hoa Ward, Thuan An City, Binh Duong Province

Email: adminbd@gsbattery.vn

Phone number: 02743756360