DATA PRIVACY POLICY FOR CUSTOMERS

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DATA PRIVACY POLICY FOR CUSTOMERS

DATA PRIVACY POLICY FOR CUSTOMERS

I. PURPOSE

Pharmacity Joint Stock Company and its Branches, Business Locations (“Pharmacity” or “We”) are committed to strictly complying with legal regulations, especially personal data protection laws. We always prioritize the protection of our Customers’ information and ensure transparency in all activities related to the collection, storage, processing, use, and sharing of personal data. Therefore, this Data Privacy Policy (“Policy”) is established and communicated to provide our Customers with clear and comprehensive information on how we collect, store, process, use, and share personal data when the Customers access and use the products and services provided by Pharmacity through our website, application, and other available channels.

II. APPLICABILITY

This policy is an integral part of the Contracts, General trading conditions, Terms and Conditions of Use for Pharmacity’s products and services. This policy applies to all platforms, including but not limited to websites, applications, media, tools on websites, applications, and other available channels of Pharmacity.
To the extent permitted by law, Pharmacity reserves the right to amend this policy at any time and will publicly post the amended Policy on Pharmacity’s website, application and other official channels. We encourage the Customers to read this policy carefully and regularly check Pharmacity’s channels to promptly update any changes we may make.
By checking the box “I have read and accepted” or “I agree with Pharmacity’s Policy and Terms of Use” or by signing a contract with Pharmacity that references this policy (and its amendments), or by registering, logging in, using Pharmacity’s website, application, or using Pharmacity’s products and services without any objections to this Policy (and its amendments), the Customers confirm that they have read, understood, and fully accepted this Policy and any changes (if any) made by Pharmacity from time to time. If the Customers do not agree with all or part of this Policy, please do not use Pharmacity’s website, application, tools on website, application, and other available channels.

III. GLOSSARY

Pharmacity: means Pharmacity Pharmacy Joint Stock Company, Business Code 0311770883, is headquartered at 248A No Trang Long, Ward 12, Binh Thanh District, Ho Chi Minh City.
Customers: this term refers to organizations, individuals, or legal representatives of organizations/ individuals who are also data subjects. It includes, but is not limited to, those who interact with, transact with, or access the Pharmacity website, application and other available channels, or use Pharmacity’s products, goods, and services (including direct transactions at Pharmacity’s stores), as well as participants in Pharmacity’s programs and events.
Products, Goods, Services: This term refers to any products, goods, or services provided by Pharmacity, either independently or in collaboration with partners, to Customers.
Personal Data: This term refers to information in the form of symbols, written text, numbers, images, sounds, or similar formats in a digital environment that is associated with a specific Customer or helps identify a specific Customer.
Processing of Personal Data: This term refers to performing one or more actions that affect personal data, including collecting, copying, recording, analyzing, storing, modifying, making public, combining, accessing, retrieving, revoking, encrypting, decrypting, sharing, transmitting, providing, transferring, deleting, or destroying personal data as well as related actions.
Third Party: This term refers to any organization or individual other than the Customer and Pharmacity that is involved with personal data or personal data processing activities.
Personal Data Protection: This term refers to measures for preventing, detecting, stopping, and addressing actions that infringe upon, collect, use, disclose, or process personal data in violation of legal regulations, with the aim of ensuring the safety and rights of personal data subjects.

IV. CATEGORIES OF PERSONAL DATA COLLECTED BY PHARMACITY

The types of personal data collected by Pharmacity include, but are not limited to, and may vary depending on the time, product, service, or interaction between the Customer and Pharmacity, including:

1. Basic personal data:

a. Surname, middle name, and given name, other names (if any);
b. Date of birth; date of death or missing;
c. Gender;
d. Place of birth, place of birth registration, permanent residence, temporary residence, current residence, hometown, contact address;
e. Nationality
f. Images, voice, and other personal identification characteristics of the Customer when attending a program or event of Pharmacity or using Pharmacity’s products or services;
g. Hobbies, habits;
h. Transactions that the Customer has made with Pharmacity, such as types and quantities of products purchased, location, time of transaction, and data on the Customer’s interactions with Pharmacity’s products or third-party products related to Pharmacity’s products;
i. Phone number, identity card number, personal identification number, passport number, driver’s license number, vehicle registration number, personal tax code, social insurance number, health insurance number;
j. Marital status; information about family relationships (parents, children);
k. Information about personal digital accounts; personal data reflecting activities and history on the internet;
l. Data required by Pharmacity to participate in and/ or apply for Pharmacity’s promotional programs or events (e.g., student card, exam transcript, marriage certificate, etc.) depending on the conditions of each program or event;
m. Information collected automatically including operating system, software, location, browser, IP address, cookies, device identifier, and information accessed when the Customer uses Pharmacity’s website/ application and other available channels, including language settings, date and time of connection to the website/ application, application usage statistics, application settings; account name; password; security login details and any other information automatically recorded from the connection;
n. Data generated/ extracted related to the Customer’s interests in advertisements; clickstream data; browsing history; responses to direct marketing and opt-out choices for direct marketing; other related data and information;
o. Other information associated with a specific individual or that helps identify a specific individual and does not fall under sensitive personal data.

2. Sensitive personal data

Personal data associated with an individual’s privacy, which, if violated, will directly affect the individual’s legitimate rights and interests, including:

a. Political viewpoints, religious beliefs;
b. Health status and personal information recorded in medical records, excluding blood type information;
c. Information related to racial and ethnic origin;
d. Information about inherited or acquired genetic characteristics of an individual;
e. Information about the physical attributes and unique biological characteristics of an individual;
f. Information about individual’s sex life and sexual orientation;
g. Customer information of credit institutions, foreign bank branches, intermediary payment service providers, and other permitted organizations, including customer identification information as prescribed by law, information of account, deposit, asset, transaction, and information about organizations and individuals who are guarantors at credit institutions, foreign bank branches, and intermediary payment service providers;
h. Data on crimes and criminal behavior collected and stored by law enforcement agencies;
i. Data on an individual’s location determined through location services;
j. Other personal data specified by law as unique and requiring necessary security measures.

V. METHODS OF PERSONAL DATA COLLECTION

Pharmacity may collect Customer data by one or all of the following methods:

1. Directly from customer and/ or applications:

a. When Customers search, register, log in, create an account, access, transact, or interact through the available channels of Pharmacity (website, app, Facebook, Zalo) or third parties related to Pharmacity’s products;
b. When Customers download the Pharmacity application for mobile devices;
c. When Customers make purchases of goods or services from Pharmacity;
d. When Customers make payments or provide details for payment processing;
e. When Customers enter into any agreements or provide documents or other information related to their interactions with Pharmacity;
f. When Customers provide feedback, inquiries, or complaints to Pharmacity, or submit any personal data to Pharmacity, Pharmacity will respond and has the full right to use the issues submitted by Customers to improve our products and services, and/ or update the content of Customer inquiries without any notice or permission required from the Customers;
g. From recording devices, including security camera systems installed at Pharmacity stores or locations where Pharmacity conducts part or all of our business activities, where Customers appear, meet, or interact with us. We always provide clear warnings or notifications to inform Customers about the collection of this information or personal data;
h. From interactions and communications between Pharmacity and Customers, including offline meetings, correspondence, phone calls (which may be recorded), online meetings, electronic communications, or any other means, including surveys, programs, events, and activities that Customers participate in;
i. Pharmacity applications may collect information about the location of Customers’ mobile devices using technologies like GPS and Wi-Fi for one or more purposes, including but not limited to location-based services requested by Customers (e.g., delivery services) or to provide Customers with information related to that location (e.g., finding a store, picking up orders at store based on Customer choices) or to allow sharing of Customers’ location with Pharmacity’s partners as part of Pharmacity’s services.

Please note that when Customers provide personal data of a third party (such as information about their spouse, children, and/or parents and/or guardians, friends, beneficiaries, authorized persons, partners, guarantors, emergency contacts, legal representatives, chief accountants, contact points, shareholders, or other individuals related to the Customers) to Pharmacity, the Customers warrant and ensure that they have fully informed the third party about the content of this Policy and have obtained the third party’s legal consent for Pharmacity to process their personal data for the purposes stated in this Policy. Additionally, the Customers understand that Pharmacity will not need to verify this consent.

2. From other third parties

a. From suppliers, service providers, partners, or parties related to Pharmacity and/ or Customers;
b. From any legal representative of the Customer related to the provision and processing of the Customer’s personal data;
c. From any publicly available information sources or social media platforms (Google, Facebook, Zalo, etc.) that the Customer has posted or updated;
d. From law enforcement agencies and public authorities as required by law;
e. From the Customer’s interaction with third-party content or advertisements on Pharmacity’s website/ application (according to the current legal privacy policy of that third party).

Whenever such personal data is collected, Pharmacity will require the third party to provide a commitment that they have obtained the corresponding consent of the Customer and will be exempt from any responsibility to re-verify this consent, regarding: (i) the sharing of personal data from the third party to Pharmacity; and (ii) the processing of the Customer’s personal data in accordance with the Policy published by Pharmacity.

VI. THE PURPOSE OF COLLECTING AND PROCESSING THE CUSTOMERS’S PERSONAL DATA

Pharmacity collects and processes the Customer’s personal data for one or more of the following purposes:

a. Identifying, authenticating, and verifying Customer information;
b. Maintaining communication, informing Customers about information related to transactions, organizing introductions and commercial promotions, product introductions, advertising, promotions for products and services provided by Pharmacity; addressing and responding to inquiries, feedback; investigating and resolving Customer complaints or requests;
c. Conducting customer care activities and after-sales programs;
d. Confirming and executing financial transactions related to Customer payments;
e. Processing Customer requests and orders; delivering products to Customers;
f. Providing products, services, or supporting Customers in using Pharmacity’s and/ or Pharmacity’s Partners’ products/ services (according to cooperation agreement) as requested by the Customer;
g. Developing and improving the quality of Pharmacity’s products/ services or features, enhancing Customer experience; improving the interface and/ or content on Pharmacity’s websites and applications to better serve Customers;
h. Developing new features and products, and supporting payment and financial solutions related to transactions;
i. Conducting market research, trend analysis, statistics, surveys, and data analysis related to products;
j. For auditing purposes, providing information to Pharmacity’s consulting units;
k. Detecting, issuing safety warnings, preventing, and combating fraud, identity theft, and other illegal activities;
l. Other purposes not mentioned here but determined by Pharmacity to be beneficial for Customers and appropriate at any given time, or any other purposes required or permitted by law.

Pharmacity processes the Customer’s personal data for one or all of the purposes mentioned above, depending on the nature and extent of the Customer’s transactions. The Customer has the right to refuse permission for Pharmacity to process their personal data for one or more of the purposes mentioned above by sending a request to Pharmacity using the contact information provided in this Policy. If we do not receive any request from the Customer, by the Customer expressing consent as mentioned in Point 3, Section II of this Policy, we understands that the Customer voluntarily agrees to allow Pharmacity full rights to process the Customer’s personal data for all the purposes mentioned above.

In the case that the Customer has agreed to allow Pharmacity to use their personal data for the purpose of marketing services, product introductions, and advertising goods/ services, the Customer agrees that we has the right to introduce goods, products and services according to the following content, method, and frequency:

(i). Content: Marketing and introducing products of Pharmacity and its partners.
(ii). Method: Through advertising messages, notifications on official websites, applications, or other methods as prescribed by law.
(iii). Form: Pharmacity sends directly to the Customer via the internet, electronic devices, or other forms as prescribed by law.
(iv). Frequency: According to Pharmacity’s regulations and legal advertising requirements (if any).

VII. ORGANIZATIONS AND INDIVIDUALS AUTHORIZED TO PROCESS THE CUSTOMER’S PERSONAL DATA

Entities authorized to process the Customer’s personal data include the following:

Pharmacity (including personnel of Pharmacity assigned to process the Customer’s personal data).
Parent company, subsidiaries, and affiliated companies of Pharmacity.
Partners, agents, suppliers, contractors, and consultants collaborating with Pharmacity, where sharing or disclosing data to them is necessary for Pharmacity to fulfill the obligations to our Customers
Companies providing payment services and related services for transactions through Pharmacity’s website, application, or e-commerce platform services.
Companies or service providers supplying products or services to Pharmacity, including but not limited to accounting, auditing, valuation, appraisal, information technology services, marketing services, market research, training services, legal services, transportation services, and other services.
Parties that have engaged in or intend to engage in transactions for the sale, transfer, or assignment of business and/or assets and/or capital contributions, shares of Pharmacity.
Third parties responsible for processing personal data under their contracts or agreements with Pharmacity, including research companies, survey firms, and rating agencies.
Parties that the Customer has consented to or that Pharmacity has a legal basis to share the Customer’s personal data with.
Competent state authorities or other third parties that Pharmacity is permitted or required to disclose to under legal regulations andor Pharmacity’s legal agreements with third parties.

VIII. STORING AND PROTECTING CUSTOMERS’ PERSONAL DATA

Customers’ personal data is stored and processed from the moment Pharmacity legally receives the personal data and has the appropriate legal basis to process the data in accordance with the law.
Pharmacity commits to only storing and processing customers’ personal data for purposes related to those stated in this Policy.
The processing of customers’ personal data will cease when the customer requests Pharmacity to stop processing or when Pharmacity no longer has any obligations to provide goods or services to the customer, or at another time as prescribed by law, except in cases where it is necessary to store customers’ personal data to achieve the purposes stated in this Policy and/ or comply with current legal regulations and/ or requests from competent state authorities.
Within the limits of the law, Pharmacity may store customers’ personal data in Vietnam and abroad, depending on the circumstances.
Customers’ personal data is committed to being kept confidential in accordance with Pharmacity’s regulations and the law. Apart from these regulations, Pharmacity will not disclose customers’ personal data to any third party unless: (i) with the customer’s consent; (ii) Pharmacity is required or permitted to disclose it by law; (iii) Pharmacity transfers rights and obligations under the agreement(s) between the customer and Pharmacity.
To provide customers with added value and the best experience, Pharmacity may choose to link to various third-party websites. These websites have their own privacy policies and security measures, which are independent of Pharmacity. We do not control and are not responsible for any content, security measures, or activities of these linked websites. Customers should consider and take responsibility when accessing them.
Pharmacity uses various information security technologies to protect customers’ personal data from unauthorized access, search, use, or sharing. However, no system is absolutely secure. We commit to making the utmost effort within our capabilities, but customers should be aware of the potential risks, consequences, and unwanted damages that may occur, including but not limited to:
a. Hardware or software errors during data processing that result in the loss of data;
b. Security vulnerabilities beyond Pharmacity’s control, where related systems are hacked, leading to data breaches;
c. Customers inadvertently disclose personal data due to carelessness or are deceived into accessing websites or downloading applications containing malware, etc.
Pharmacity recommends Customers to keep information related to account login passwords and OTP codes confidential and not to share this information with anyone else.
Customers should secure their electronic devices during use; lock, log out, or exit their accounts on Pharmacity’s website or application when not in use.
In the event of an incident or detection of a violation involving customers’ personal data, Pharmacity will immediately notify the competent state authorities of the data protection violation and strive to implement remedial measures to prevent consequences.

IX. COOKIES

When customers use or access Pharmacity’s websites or online information pages (hereinafter collectively referred to as ‘websites’), we may place one or more cookies on the Customer’s device. A ‘cookie’ is a small file that records information about the device, the Customer’s browser, and in some cases, the Customer’s preferences and browsing habits. Pharmacity may use cookies to recognize Customers when they return to the websites, to provide personalized services, and to collect and analyze data to better understand and improve Pharmacity’s websites. Customers can delete or block cookies on their devices through browser settings. However, refusing or blocking cookies may limit the experience and some features on Pharmacity’s websites.
Pharmacity may collect and process customers’ personal data through cookie technology. Additionally, Pharmacity may apply retargeting methods to display advertisements to customers who have previously visited its websites.
In some cases, third parties may provide content or services on Pharmacity’s websites. If customers interact with the content or use services from these third parties, they may collect customers’ personal data through cookies.

X. PROCESS PERSONAL DATA WITHOUT THE DATA SUBJECT’S CONSENT

Pharmacity may process customers’ personal data without the customer’s consent in cases that comply with legal regulations on personal data protection as follows:

In emergency cases, it is necessary to immediately process relevant personal data to protect the life and health of the data subject or others.
Publicize personal data as required by law.
Handling data by competent state agencies in cases of emergencies related to national defense, national security, social order and safety, major disasters, dangerous epidemics; when there is a threat to security and defense but not to the extent of declaring a state of emergency; preventing and combating riots, terrorism, crime, and legal violations as prescribed by law.
Fulfilling contractual obligations of the data subject with relevant agencies, organizations, and individuals as prescribed by law.
Serving the activities of state agencies as prescribed by specialized laws.

XI. RIGHTS AND OBLIGATIONS OF CUSTOMERS

1. Unless otherwise provided by law, as the Data subject, the Customer has the following rights:

a. To be informed about the processing activities of their personal data;
b. To consent or refuse consent to the processing of their personal data, except in cases where the processing of personal data does not require the Customer’s consent as prescribed by relevant laws;
c. To withdraw consent for the processing of personal data at any time. This withdrawal does not affect the legality of data processing that occurred based on the Customer’s prior consent. However, withdrawing consent may lead to certain legal consequences and affect the use of the Customer’s products, services, and utilities on Pharmacity’s website, application, and other available channels. We may need to limit, suspend, or terminate the continued provision of goods, products, and services to the Customer or may need to terminate the transactional relationship between Pharmacity and the Customer. This change may result in costs and damages that the Customer and/ or third parties will have to bear. Pharmacity will not be liable for any legal responsibility or compensation for any losses arising from the Customer’s decision to withdraw consent;
d. To access, view, edit, or request the editing of their personal data; to delete or request the deletion of their personal data. Pharmacity may require the Customer to provide additional information to verify their identity and understand the Customer’s request before proceeding. Pharmacity will review, evaluate, and address the Customer’s request in accordance with legal regulations. In some cases, we may refuse to edit or delete personal data if the request does not comply with current regulations;
e. To request the restriction of the processing of their personal data. The restriction of data processing will be implemented by Pharmacity within 72 hours after the Customer’s request for all personal data that the Customer requests to be restricted;
f. To request Pharmacity to provide their personal data. Within 72 hours of receiving a valid request from the Customer, Pharmacity will notify the Customer of the time, place, and method of providing the personal data; the actual costs incurred for printing, copying, photographing, sending information via postal services, fax (if any), and the method and deadline for payment. If the requested personal data is not within Pharmacity’s authority, we will clearly state the reason and guide the Customer to contact the relevant organization/ authority or clearly state the case where we cannot provide the personal data;
g. To object to Pharmacity and/or authorized parties controlling and processing personal data as stipulated in this Policy from processing their personal data to prevent or limit the disclosure of personal data or the use of personal data for purposes contrary to this Policy. We will fulfill the Customer’s request within 72 hours of receiving a valid request. However, if the Customer’s objection affects the performance of the contract between Pharmacity and the Customer, Pharmacity’s legal obligations, the property, rights, and legitimate interests of other organizations or individuals, or the duty to protect national security and social order, Pharmacity has the right to limit, suspend, or terminate partially or entirely the provision of products, goods, and services to the Customer;
h. To file complaints, denunciations, or lawsuits in accordance with the law;
i. To request compensation for damages in accordance with the law in case of violations of personal data protection regulations, unless otherwise agreed by the parties or provided by law;
j. To self-protect in accordance with the Civil Code, other relevant laws, and Decree 13/2023/ND-CP on personal data protection; or to request competent agencies and organizations to implement methods to protect civil rights as stipulated in Article 11 of the Civil Code;
k. Other rights as prescribed by current laws.

2. Obligations of Customers

a. To comply with the laws, policies, regulations, and guidelines of Pharmacity related to the processing of the Customer’s personal data;
b. To provide complete, honest, and accurate personal data and other information as required by Pharmacity when registering and using Pharmacity’s products and services, and when there are changes to this information. We will secure the Customer’s personal data based on the information the Customer has registered. Therefore, if there is any incorrect information, we will not be responsible if such information affects or limits the Customer’s benefits. In case of failure to notify, if any risks or losses arise, the Customer will be responsible for any errors or acts of exploitation or fraud when using the service due to their fault or due to not providing correct, complete, accurate, and timely information changes; including financial losses and costs incurred due to incorrect or inconsistent information provided;
c. To cooperate with Pharmacity, competent state agencies, or third parties in case issues arise affecting the security of the Customer’s personal data;
d. To protect their personal data; to proactively apply measures to protect their personal data while using Pharmacity’s products and services; to promptly notify Pharmacity when they detect any errors or mistakes in their personal data or suspect that their personal data is being compromised. Pharmacity is exempt from liability for any damages to the Customer in case the Customer’s password is disclosed/lost or stolen, leading to unauthorized access to the account, or any activities on the Customer’s account using a lost or misplaced mobile device, resulting in unauthorized use of the Customer’s account on Pharmacity’s system;
e. To take responsibility for the information, data, and consents they create and provide; to take responsibility in case their personal data is leaked or compromised due to their own fault;
f. To regularly update themselves on Pharmacity’s Regulations and Policies as notified to Customers or posted on Pharmacity’s website, application, and other available channels from time to time. To take actions as guided by Pharmacity to clearly indicate their consent or non-consent for the purposes of personal data processing that Pharmacity notifies to Customers from time to time;
g. To respect and protect the personal data of others;
h. Other obligations as prescribed by law.

XII. UPDATING, AMENDING, AND SUPPLEMENTING POLICIES

Unless otherwise provided by law, Pharmacity has the right to amend and supplement this Policy at any time and publicly announce it on Pharmacity’s electronic information pages, applications, or other official communication channels, or by other appropriate means (if any) without prior notice. Unless otherwise specified regarding the effective date, the amendments and supplements will take effect immediately upon being announced by Pharmacity. The Customer’s continued use of Pharmacity’s products and services immediately after the amendments and supplements to the Policy take effect signifies the Customer’s acceptance of those amendments and supplements.
Pharmacity will strive to notify Customers of any amendments and additions in a timely manner. However, our notifications may not reach all customers due to technical issues that are beyond our control and not desired. Therefore, we encourage and recommend that Customers regularly visit Pharmacity’s websites, applications, or other official channels to stay updated with the latest information regarding this policy or related regulations.

XIII. CONTACT INFORMATION

To exercise their rights, or if Customers have any questions related to this Policy, or if they need to discuss issues related to Data subject rights or personal data processing under this Policy, Customers can contact us through one of the following channels:

(i). Send a letter to Pharmacity at the address: 248A No Trang Long, Ward 12, Binh Thanh District, Ho Chi Minh City
(ii). Send an email to: [email protected]
(iii). Hotline: 1800 6821 – Customer Care

XIV. GENERAL TERMS

This policy has been effective since July 1, 2023, and was updated on March 01, 2025.
Customers confirm that they have thoroughly read, clearly understood their rights and obligations, and agree with the content of this Policy, including the Personal Data Processing Notice stipulated in Article 13 of Decree 13/NĐ-CP/2023 and any amendments and supplements from time to time, which are posted on Pharmacity’s website. Therefore, Pharmacity does not need to take any additional notification measures regarding the processing of Customers’ personal data.
Customers commit to strictly complying with the provisions of this Policy. For issues not yet regulated, the Parties agree to follow the provisions of the law, the guidance of competent State agencies, and/ or the amendments and supplements notified by Pharmacity from time to time.
This Policy is entered into on the basis of goodwill between Pharmacity and the Customers. In the event of a dispute arising during the implementation, the Parties will proactively resolve it through negotiation and mediation. If mediation fails, the dispute will be brought to the competent People’s Court for resolution in accordance with the law.
Matters related to personal data processing that are not specified in this Policy will comply with the current legal regulations.