The privacy policy (“Privacy Policy”) is an integral part of the Website terms of use governing the relationship between the Company and the user who accesses to the Company’s website(“Website”) and/or a potential customer who is interest in the service provided by the Company (collectively referred to as the “Member” or “User”) and should be read in conjunction with any of the terms and conditions entered into between the User and the Company.

“Personal Data” in the Privacy Policy means data which enables an individual to be identified including, but not limited to, information such as names, contact details, addresses and other identification details of the User who access the Website or any of the services provided by the Company through the Website (“Services”) or any of the Services, signatures, answers to questions intended for security verification, emergency contact numbers or call back contact details provided or made available to us when any User accesses the Website.

From time to time, the Company may collect Personal Data from (a) the User, (b) third parties, including User’s beneficial owners, partners, directors, officers or authorized signatories, employees, customers, payors, payees, guarantors, other security providers and other natural persons related to that user (the “Relevant Individuals”) ) and/or (c) publicly available sources including credit bureaus, Personal Data about the Users, Relevant Individuals and related parties in connection with the access and use of the Website or any of the Services to provide more personalized service for our User. This may include:

I. The use of cookies in the Website and in the provision of the Services;

II. Collection of information in relation to the devices (including device operating system, hardware version, settings, file and software names and types and device identifiers, device location, connection information such as the name of the ISP or mobile operator to access the Website.

Should the Member provide the Company any Personal Data of yourself or others:

I. The Member represents and warrants to the Company that (x) each individual (including yourself) whose Personal Data has been provided to us, has been notified of the purposes for which data5 will be collected, processed, used or disclosed; and (y) such individual’s consent for the collection, processing, use and disclosure of such Personal Data by MPV has been obtained and authorized by such individual;

II. The Member shall notify us immediately upon becoming aware of any withdrawal by any individual of his/her consent to the collection, processing, use and/or disclosure by the Company of his/her Personal Data provided to the Company. The withdrawal of such consent may affect the services which the Company is able to provide to the Members, such individual and/or the corporate the Members represent (including possible termination of contractual relationship of the Members with us, subject to termination provisions relating to registered users and may be deemed a breach of representation and undertakings of the Member to us).

III. The Member shall ensure at all times that any information provided (including any Personal Data) to us is correct, accurate and complete, and that any consent given in relation to Personal Data shall, subject to all applicable laws and regulations, survive death, incapacity, bankruptcy or insolvency of any such individual and the termination or expiration of any account in connection with the use of the Website.

Personal Data submitted or collected by the Company may be used by the Company for any of its business purposes, including (the“Purposes”):

I. To operate, administer any account and to provide Services to any User through the Website including, but not limited to, facilitating the transfer of funds, maintaining accurate “know your customer” information, to verify the identities or authorities of the User and/or their representatives who contact the Company or may be contacted by the Company, to carry out or respond to requests, questions or instructions from the User and/or their representatives, and to perform risk modeling or analysis;

II. To facilitate transactions on the Website or in connection with the Services;

III. To comply with the terms of use of the Website, the Privacy Policy and any other terms and conditions as may be stipulated by the Company from time to time and at any time;

IV. To verify the identity or authority of the User and/or representatives of the User and/or to pursuant to current security procedures or internal procedures of the Company;

V. In the assessment and evaluation of viability, credibility, suitability, eligibility and identity of the User in connection with the Services, and/or any other documents entered into or agreed to by such User;

VI. To carry out, monitor and analyze the Company’ business;

VII. For the marketing, promotion or advertisement of products and services (including any other financial services) which the Company believes the Member may be interested in;

VIII. As part of, or in connection with, any sale, merger, or similar change of the Company’s business;

IX. For customer feedback and complaints or legal purposes in enforcing the Company’s rights, drafting and reviewing of documents, procuring legal advice and dispute resolution;

X. To comply with any applicable laws, rules, or regulations in any country;

XI. To detect, prevent and investigate fraud, crime, offenses, money-laundering, counter-terrorist financing and bribery;

XII. Purposes reasonably related to the aforesaid.

The Company may retain Personal Data for so long as one or more of the purpose for which it was collected remains valid, where required by regulation or law including other jurisdictions outside of Vietnam, or as required by its own record retention policies or own business purposes.

The Company may from time to time also disclose Personal Data for any of the Purposes to the Company’s shareholders, directors, officers and employees and the following parties (whether inside or outside of Vietnam):

I. Any agent, contractor, or third party service provider who provides banking, remittance, administrative, mailing, telecommunications, call centers, business process, travel, visa, knowledge management, human resource, data processing, information technology, computer, payment, debt collection, credit reference checks or securities clearing or risk modeling or analysis or other services to MPV in connection with the business operations of the Company and/or the operation of the Website or any of the Services;

II. Any person or entity employed by or on behalf of the Company or is a part of or related to any group of companies of which the Company forms part or is affiliated to;

III. Any person or entity to whom the Company is under an obligation or otherwise required to make disclosure pursuant to any applicable laws and regulations, including disclosure to courts, tribunals, and/or legal, regulatory, tax and government authorities and stock exchanges;

IV. Any party giving or proposing to give a guarantee or third-party security to guarantee or secure the obligations of any User;

V. Any party for purposes of conducting checks with the Do Not Call Registry;

VI. Any party for purposes of meeting or complying with the Company’s internal policies and procedures and any applicable rules, laws, regulations, codes of practice or guidelines, orders or requests issued by any court, legal or regulatory bodies including other jurisdictions outside of Vietnam (including but not limited to disclosures to regulatory bodies, conducting audit checks or any investigations);

VII. Any actual or proposed assignee of MPV or transferee of MPV’ rights in respect of all or any part of the assets or business of MPV;

VIII. Any credit bureau as well as the members of such credit bureau and other relevant third parties in connection with the use of the Website as required by law or regulation.

Without prejudice to the foregoing, the Company may disclose Personal Data to any person or entity to whom the Company is under an obligation or otherwise required to make disclosure pursuant to any applicable laws7 and regulations, including disclosure to courts, tribunals, and/or legal, regulatory, tax and government authorities in Vietnam or otherwise.

The Members may access or make corrections to any of Personal Data of the Members held by the Company. To do so, please contact the Company at support@mpvn.com.vn. The Company reserves the right to charge the fees as it may, in its sole and absolute discretion, deem appropriate for the grant of such access and to correct any Personal Data.

The Company may from time to time send the Members and/or the Relevant Individuals email messages or short message service (“SMS”) to mobile phones based on Personal Data provided to the Company. The Company do not guarantee that these messages will be completely secure. Under no circumstance will the Company be liable for any damages incurred or sustained by the Members or the Relevant Individuals in connection with or arising from any such messages transmitted by the Company or to the Company.