PART 1: INTRODUCTION

The website export.adtrue.com and FPT AdTrue Export (“FPT AdTrue Export”) are developed, owned, used, and operated by FPT AdTrue Joint Stock Company (“the Company” or “AdTrue”).

These Terms of Use set forth the general principles and conditions governing user activities on FPT AdTrue Export in order to ensure compliance with applicable laws. By specifying your rights and obligations when participating in activities on FPT AdTrue Export, as well as those of FPT AdTrue Export, we strive to provide you with an engaging, safe, and legally compliant environment. This Policy is governed by the Law on Cyberinformation Security 2015, Decree No. 13/2023/ND-CP on Personal Data Protection, and other relevant legal provisions of Vietnam.

The provisions of these Terms of Use are publicly posted on export.adtrue.com and the FPT AdTrue Export platform, and constitute a full agreement between you and the Company, as well as with other users, regarding all activities conducted on FPT AdTrue Export.

Before engaging in any activities on FPT AdTrue Export, you are required to ensure that you have read, understood, and clicked “Agree” to all the contents set forth by the Company below. From the moment you click “Agree,” these Terms shall have the same binding effect as a legally executed contract between you and the Company. Furthermore, you acknowledge and accept that these Terms of Use may be amended or supplemented at any time at the Company’s sole discretion, without prior consultation with any user. Such changes and updates shall take immediate effect when you continue to use FPT AdTrue Export.

In the event of any violations or disputes arising from your failure to comply fully with these Terms, you shall bear full responsibility before the Company, any third party whose legitimate rights and interests are affected, or before the law.

PART 2: INFORMATION AND PERSONAL DATA PRIVACY POLICY

1. User Rights

1.1. Users have the right to be informed about data processing activities (including automated data processing) with respect to their Personal Data, as stipulated in these Terms of Use and/or under notices issued by FPT AdTrue Export, which Users confirm they have read, understood, and taken actions to continue providing consent for data processing.

1.2. Users have the right to access their Account section to view, edit, or request corrections to their Personal Data.

1.3. Users have the right to withdraw their consent for the processing of their Personal Data, request restrictions on processing, object to data processing, or request the Company to provide their Personal Data by directly contacting the Company through the customer support contact information provided on FPT AdTrue Export to submit such requests.

1.4. Users may request deletion of the Personal Data collected by the Company by selecting the “Delete Account” function made available by the Company on FPT AdTrue Export and following the steps outlined in the Company’s published guidance on FPT AdTrue Export.

1.5. Users have the right to file complaints, denunciations, lawsuits, or request compensation from the Company for damages arising from violations of Personal Data protection regulations as stipulated in these Terms of Use.

1.6. Users have the right to protect their Personal Data in accordance with the Civil Code, other relevant laws, and/or request competent authorities and organizations to implement measures to safeguard civil rights as prescribed by the Civil Code.

1.7. Other rights as provided by law.

2. User Obligations

2.1. Protect their own Personal Data and request the Company to protect their Personal Data.

2.2. Respect and safeguard the Personal Data of other Users on FPT AdTrue Export.

2.3. Provide complete and accurate Personal Data.

2.4. Comply with applicable laws on Personal Data protection and participate in the prevention and combat of violations against Personal Data protection regulations.

2.5. Fulfill other obligations as prescribed by law.

3. User Consent

User consent for the processing of Personal Data on FPT AdTrue Export is expressed by checking the “Agree” box and clicking the confirmation button to acknowledge that they have read and understood the contents of the Personal Data Protection Policy stipulated in these Terms of Use and/or by clicking the “Agree” button to proceed with data processing notices displayed by the Company on the screen when using FPT AdTrue Export.

4. Rights and Obligations of the Company

4.1. Use and process Users’ Personal Data in accordance with these Terms of Use and applicable laws.

4.2. Maintain a communication channel for receiving User requests related to Personal Data, as stipulated in Section 1 of these Terms of Use.

4.3. Protect the confidentiality of Users’ Personal Data in accordance with these Terms and applicable laws.

4.4. Implement all necessary measures to safeguard Personal Data as required by law.

4.5. Be liable to Users for damages arising from the processing of Personal Data.

4.6. Delete Users’ Personal Data upon completion of data processing or at the request of the User, except where otherwise provided by law or where retention is necessary for the purposes of fraud prevention, protection against account impersonation, or resolving contractual matters.

4.7. Be liable to Users for damages arising from the processing of Personal Data.

4.8. Exercise other rights and perform other obligations as prescribed by law.

5. Collection of Personal Data

5.1. The Company collects Users’ Personal Data in accordance with these Terms of Use and in compliance with applicable laws.

5.2. The Company collects Users’ Personal Data through the following methods:

5.2.1. Users provide Personal Data to the Company by filling in or entering data into the account registration form or other forms displayed when using the features of FPT AdTrue Export.

5.2.2. Users provide Personal Data directly to the Company via the Company’s customer support contact channels, or by participating in promotional programs, contests, or events organized by the Company, or by interacting on the Company’s dedicated user channels and social media platforms.

5.2.3. Through the use of biometric solutions and functions for personal identification.

5.2.4. Via the features and functions of the software, website, or user account management platform of FPT AdTrue Export, including but not limited to transaction information, payment information, device information, user interaction behaviors, use of products on FPT AdTrue Export, and communications within FPT AdTrue Export’s communication and customer care software.

5.2.5. From partners providing information to FPT AdTrue Export in compliance with applicable laws, such as marketing and media service providers, intermediary payment service providers, credit institutions, securities companies, and fund management companies.

6. Use and Processing of Personal Data

6.1. The Company ensures that the Personal Data collected from Users is used and processed strictly in accordance with these Terms of Use and applicable laws.

6.2. The Company may use, combine, and process Users’ Personal Data for the following purposes (“Purposes”):

6.2.2. Verify Users’ identities and authenticate personal information through electronic customer identification solutions and/or other valid authentication methods.

6.2.3. Recommend and provide Products and Services to Users.

6.2.4. Introduce new services and features of FPT AdTrue Export.

6.2.5. Conduct customer care activities on FPT AdTrue Export.

6.2.6. Carry out marketing and advertising activities for FPT AdTrue Export and/or for advertisers, marketers, and commercial promotion entities.

6.2.7. Promote promotional programs, communication campaigns, products, and services on FPT AdTrue Export.

6.2.8. Support the execution and performance of contracts and transactions on FPT AdTrue Export.

6.2.9. Facilitate transactions on FPT AdTrue Export.

6.2.10. Manage Users’ activities and administer User accounts on FPT AdTrue Export.

6.2.11. Handle inquiries and complaints arising from Users’ use of FPT AdTrue Export.

6.2.12. Assess, research, and measure the relevance and level of interest between consumer behaviors and Users’ interactions with the Company’s or its partners’ products/services in order to develop new products/services on FPT AdTrue Export, as well as those of partners with whom the Company collaborates or affiliates, which the Company deems suitable for Users’ needs.

6.2.13. Prevent fraudulent, impersonation, or unlawful activities that cause damage to Users’ or the Company’s assets on FPT AdTrue Export.

7. Transfer and Disclosure of Personal Data

The Company may share Personal Data with various parties for the purposes including:

7.1. With the Company’s governing entities, subsidiaries, parent companies, or authorized shareholders in connection with the business operations, products, and services of FPT AdTrue Export.

7.2. With service providers.

7.3. With advertising, marketing, and media service providers, or entities owning marketing and affiliate platforms.

7.4. With intermediary payment service providers and commercial banks where the User or the Company holds payment accounts for deposit/withdrawal activities.

7.5. With consulting firms and market research agencies.

7.6. With data processors who have entered into contracts with the Company.

7.7. With messaging service providers.

7.8. With competent state authorities as required by law.

8. Storage and Deletion of Personal Data

8.1. Personal Data will be stored in databases and periodically backed up; the system will encrypt sensitive Personal Data to ensure the confidentiality of such information.

8.2. Personal Data will be retained by the Company for the entire period during which the User utilizes FPT AdTrue Export, or after the User Account has been locked or deleted due to violations, fraud, or impersonation, or throughout the data processing period, and shall be protected in accordance with applicable laws.

8.3. The Company shall not be held liable for unauthorized access to Users’ Personal Data in cases where Users voluntarily share their information with others.

8.4. The Company shall delete Personal Data upon the User’s request for all data previously collected, or upon completion of the processing purposes, or where such data is no longer necessary for the Purposes, except where otherwise required by law or where retention is necessary for fraud prevention, account impersonation, or for resolving contractual obligations related to violating, fraudulent, or impersonated User Accounts.

8.5. Retention period of information: from 2 years to 10 years, depending on the type of information stored, in compliance with applicable laws.

9. Cross-Border Transfer of Personal Data

For the purposes of processing Personal Data as set forth in Section 6 of these Terms of Use, the Company may need to transfer Users’ Personal Data to the parties referred to in Section 7 of these Terms of Use that are located in jurisdictions outside of Vietnam. When providing or sharing Personal Data abroad, the Company shall require the receiving party to ensure that the transferred Personal Data of Users is kept confidential and secure, and that such transfer complies with the requirements of applicable Vietnamese laws.

10. Duration of Personal Data Processing

Users’ Personal Data shall be processed immediately upon collection into the systems of the Company and/or the Company’s partners and/or third parties involved in the Company’s data processing activities, until such time as either the User or the Company has fulfilled all obligations to the other party under the Contract, and the User requests deletion of Personal Data or withdraws consent.

The User understands and agrees that, with respect to data processing activities for the purpose of preventing and addressing fraudulent, impersonation, or unlawful activities related to the User’s Account, reporting to competent state authorities shall be carried out in accordance with applicable laws from time to time and/or the Company’s internal regulations, and such activities shall not be limited by the Personal Data Protection Policy under these Terms of Use.