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 IPA-NIMA Privacy Policy

 Purpose and Scope

 This Privacy Policy explains how IPA-NIMA collects, uses, transfers, and discloses Personal Data (as defined in this Privacy Policy) that you provide directly to us or that we receive via our website accessed through any medium, including via computer, mobile device, or other devices. This Privacy Policy also outlines your rights in respect to your Personal Data.

IPA-NIMA VIETNAM LLC, IPA-NIMA VIETNAM HOLDINGS JSC (collectively referred to as “IPA-NIMA”, “we”, “us” and “our” in this privacy notice) is the controller and is responsible for your personal data collected through the www.ipa-nima.com website. 

You can contact us at Enquiry@ipa-nima.com in the first instance.

Ipa-nima.com provides you with the ability to purchase product and courier service offerings via its website. Each offering may be subject to specific privacy policies which may supersede or complement the terms of this privacy policy. IPA-NIMA encourages you to carefully read the privacy policy of the relevant offering before accessing or using that offering.

 Although we encourage you to read this entire Privacy Policy, this is a summary of some of the more important aspects:

 - Each Offering may include its own specific privacy policy. You should carefully read the privacy policy of any Offering before accessing or using that Offering.

- We may collect Personal Data and other information from you through a variety of sources, including Personal Data we have collected from you, on or offline. We may also combine it with information we receive about you from other sources, such as affiliates, publicly available information sources (including information from your publicly available social media profiles), and other third parties.

- We will not use or share your Personal Data except as described in this Privacy Policy.

- Where applicable, we honour opt-out instructions from you for certain uses of your Personal Data under this Privacy Policy, such as, for example, when you opt out of receiving marketing email communications from us or request us to delete your Personal Data.

- We use appropriate technical and organisational controls to secure and protect your Personal Data. While we cannot ensure or warrant that your Personal Data will be completely secure from misappropriation by hackers or from other nefarious or criminal activities, we believe that our measures reduce the risk of such activities happening.

General Principles for the Processing of Personal Data

Personal Data will be collected, stored, processed, and transmitted in accordance with our established policies and applicable local and international laws, rules, and regulations.

The principles of this Policy with respect to the processing of Personal Data are as follows:

 - Personal Data will be processed fairly, lawfully, and transparently.

- Personal Data will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes.

- Personal Data collected will be adequate, relevant, and not excessive in relation to the purposes for which it is collected.

- Personal Data collected by IPA-NIMA will be accurate and, where necessary, kept up to date to the best of our ability.

- Personal Data will be protected against unauthorized access and processing using appropriate technical and organisational security measures and controls.

- Personal Data collected by IPA-NIMA will be retained as identifiable data for no longer than necessary to serve the purposes for which the Personal Data was collected.

 If IPA-NIMA engages in the processing of Personal Data for purposes other than those specified in this Privacy Policy, IPA-NIMA will provide notice of these changes, the purposes for which the Personal Data will be used, and the recipients of Personal Data.

Collection of Information

IPA-NIMA may collect Personal Data about you from a variety of sources, including directly from you, from our service providers, from third-party information providers, from our Affiliates, and through the operation of the Website.

 **Personal Data** collected by IPA-NIMA includes:

 - your first and last name;

- billing or shipping address;

- credit card or payment information;

- email address;

- phone number;

- purchase information and history;

- your account number;

- a combination of your username and password used to access the Website.

 **Sensitive Information (Special Categories of Data)**

Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership) on or through this Website or otherwise to us. In those cases where we may request or invite you to provide sensitive personal data, we will do so with your explicit consent, which you may withdraw at any time.

IPA-NIMA collects your Personal Data as follows:

**Information You Provide Voluntarily**

 We may collect Personal Data directly from you when you voluntarily provide it to us. For example, when you communicate with us over the telephone or through the Website by way of email, online chat, web form, or online account registration to obtain access to Offerings, register for an event or training, purchase an Offering, ask questions, attempt to resolve any issues related to the Website or Offerings, or submit feedback and comments.

 **Information that We Collect Automatically**

 When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Data under applicable data protection laws.

 Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser type, your Media Access Control (MAC) Address, broad geographic location (e.g., country or city-level location), and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked. We may collect online behavioural data linked to online identifiers through tracking technology and this may be matched to personal data to improve our offerings to you. We will never process your personal data unlawfully and we will also ensure your rights and freedoms are protected.

 We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors. Some of this information may be collected using cookies and similar tracking technology, as explained further under the Section below: “Cookies and Other Website Usage Information.”

 **From Third-Party Information Providers**

 IPA-NIMA may obtain Personal Data from third parties that have obtained or collected information about you and that have the right to provide that Personal Data to us. IPA-NIMA will only obtain this Personal Data where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Data to us.

 # Use of Information

 IPA-NIMA uses Personal Data we collect to operate our business and provide you with Offerings, which includes using this data to improve our Offerings and personalize your experiences. We also may use the data to communicate with you, for example, informing you about your account and product information.

 IPA-NIMA may use your Personal Data for a variety of purposes (the “Purposes”), including to:

 - Provide you with the products and services you purchase. We provide these in line with our contractual obligations to you, either directly through us or through our partners;

- Provide, maintain, and improve the Website and our Offerings, including to operate certain features and functionality of the Website;

- Understand user preferences to enhance users’ experience with IPA-NIMA and its Affiliates, contractors, and business partners;

- Research and analyze the effectiveness of the Website and the marketing, advertising, and sales efforts of IPA-NIMA, its Affiliates, contractors, and business partners;

- Process orders and payments made through the Website;

- Develop additional Offerings;

- Comply with a legal obligation or respond to lawful requests by public authorities (including national security or law enforcement requirements);

- Manage our everyday business needs;

- Enforce compliance with our Terms of Use and applicable law;

- Prosecute and/or defend a court, arbitration, or similar legal proceedings;

- Communicate directly with you by sending you newsletters, promotions, and special offers or information about new products and services on an ongoing basis in accordance with your marketing preferences. You can unsubscribe from our marketing communications by clicking “Unsubscribe” at the bottom of any communication we issue, or by contacting us;

- Communicate directly with you by email to respond to customer service inquiries or comments through the Website, social media, or otherwise, to discuss issues relating to your account or the Website, and to provide customer support;

- Deliver advertising to you, including to help advertisers and publishers serve and manage ads on the Website or on third-party sites, and to tailor ads based on your interests and browsing histories;

- Compile aggregated statistics about the operation and use of our Website and to better understand the preferences of the visitors of our Website.

We may combine and enhance the Personal Data we collect about you with other information we receive from third parties to provide you with the best service possible.

We may also use the Personal Data we collect about you through the Website to generate anonymized, aggregated data. When we do so, we ensure that the anonymized, aggregated data is no longer personally identifiable and may not later be used to identify you.

 Information Sharing

 We share your Personal Data as necessary to complete any transaction or provide any Offering you have requested or authorized or with your consent where appropriate. We also share Personal Data with vendors, resellers and distributors, service providers, Affiliates, and business units when required by law.

 We may share personal data internally with teams such as Sales, Customer Service, Finance, Marketing, and Operations to ensure your products and services are delivered in line with your purchasing agreement with us. We will only ever process this data as intended. We may do this to respond to legal processes, to protect our customers, to maintain the security of our business, and to protect the rights or property of IPA-NIMA. You can contact us anytime about how we share your data internally.

 We may disclose your Personal Data as follows:

 **Affiliates and Business Units**

IPA-NIMA may share Personal Data with our Affiliates and business units for the Purposes described in this Privacy Policy.

**Service Providers**

IPA-NIMA may share Personal Data with third-party service providers who perform services on our behalf and/or to help us provide you with the Offerings. For example, we may engage third-party service providers to provide marketing, advertising, communications, infrastructure, and IT services, to personalize and optimize our service, to process credit card transactions or other payment methods, to provide customer service, and to collect debts. When providing such services, these service providers may have access to your Personal Data. However, they are only authorized by IPA-NIMA to use or disclose your Personal Data in connection with providing their services to IPA-NIMA and are contractually obligated to ensure the confidentiality and security of your Personal Data.

**Business Transfers**

As we continue to develop our business, we may sell or buy assets or businesses. If another entity acquires us or all or substantially all of our assets, Personal Data, usage data, and any other information that we have collected about the users of the Website may be disclosed to such entity as one of the transferred assets.

**Legal Requirements**

IPA-NIMA reserves the right to disclose your Personal Data if required or permitted to do so by law or in the good faith belief that such action is necessary or appropriate to (i) comply with legal processes; (ii) respond to any claims; or (iii) protect the rights, property, or personal safety of IPA-NIMA, our customers, or the public.

 Security

IPA-NIMA will take reasonable steps to protect the information collected and provided via the Website from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error-free. In particular, email sent to or from the Website may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to IPA-NIMA via the Internet. If you have any questions about the security of your personal information, you can contact us at enquiry@ipa-nima.com.

Data Retention

We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements). When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

Your Rights and Choices

You have the following rights regarding your Personal Data:

- You may access, correct, update, or request the deletion of your Personal Data. IPA-NIMA takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You can request to access, correct, or update your Personal Data by contacting us directly at enquiry@ipa-nima.com.

- You can object to the processing of your Personal Data, ask us to restrict processing of your Personal Data, or request the portability of your Personal Data. You can exercise these rights by contacting us directly at enquiry@ipa-nima.com.

- You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Changes to the Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

Contact Us

 If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at enquiry@ipa-nima.com or by mail at:

 IPA-NIMA VIETNAM LLC – HCM BRANCH/ IPA-NIMA VIETNAM HOLDINGS JOINT STOCK COMPANY

B1, KHU BIET THU 280, LUONG DINH CUA, AN PHU, Tp THU DUC,

HO CHI MINH CITY 700000, VIETNAM

EMAIL: ENQUIRY@IPA-NIMA.COM
TEL: +84 938826716