Personal Data Processing Notice

(1) Last name, middle name and first name, other names (if any);
(2) Date of birth; date of death or going missing;
(3) Gender;
(4) Place of birth, registered place of birth; place of permanent residence; place of temporary residence; current place of residence; hometown; contact address;
(5) Nationality;
(6) Personal image; information obtained from security systems, including recordings of Personal Data Subjects’ images on camera systems, surveillance cameras at BSL’s business locations;
(7) Phone number; ID Card number, personal identification number, passport number, driver’s license number, license plate, taxpayer identification number, social security number and health insurance card number;
(8) Occupation, place of work;
(9) Marital status;
(10)Information about the individual’s family relationship (parents, children);
(11) Digital account information; personal data that reflects activities and activity history in cyberspace;
(12)Other information associated with an individual or used to identify an individual.

(1) Political and religious opinions;
(2) Health condition and personal information stated in health record, excluding information on blood group;
(3) Information about racial or ethnic origin;
(4) Information about genetic data related to an individual’s inherited or acquired genetic characteristics;
(5) Information about an individual’s own biometric or biological characteristics;
(6) Information about an individual’s sex life or sexual orientation;
(7) Data on crimes and criminal activities collected and stored by law enforcement agencies;
(8)  Information on customers of credit institutions, foreign bank branches, payment service providers and other licensed institutions, including: Data Subject’s identification as prescribed by law, accounts, deposits, deposited assets, transactions, organizations and individuals that are guarantors at credit institutions, bank branches, and payment service providers;
(9) Personal location identified via location services;
(10) Other information related to the operation, provision and evaluation of BSL’s activities, products and services in accordance with the provisions of law.

a. BSL collects Personal Data from You for the Purposes set out in Section 2.1 below, either directly or indirectly, until mutually agreed or unless otherwise provided by law, the processing of Personal Data may be performed by the Company by one or multiple activities that impact on Personal Data such as collection, recording, analysis, confirmation, storage, rectification, disclosure, combination, access, traceability, retrieval, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction of Personal Data, outbound transfer of Personal Data and/or other activities prescribed by applicable law from time to time; and
b. undertakes not to claim, file a petition or take any similar action against BSL arising out of or in connection with the Data Processing for the Purposes mentioned in this Notice.

(1) Identify, verify and maintain accurate KYC information; seek, verify and conduct anti-money laundering, credit and other checks with You as required;
(2) Evaluate, identify, assess and approve the provision of products and services according to Your registration documents and proposals;
(3) Assess, build and evaluate the level of reliability of You in using our products and services;
(4) Consider offering or continuing to provide any BSL products or services to You.

(5) Perform contractual obligations, agreements and provide products and services to You;
(6) Customer care, handling Your complaints and lawsuits;
(7) Contact you, conduct marketing directly and indirectly products and services with you, conduct promotions, exchange gifts, award prizes, deliver gifts.

(8) Gain a better understanding of your investment needs, current and future financial situation;
(9) Improve, enhance, individualize and personalize BSL’s products and services including BSL’s online service and develop new products and services;
(10) Conduct market research, surveys and data analysis related to any BSL products or services provided to You;
(11) Monitor, ensure safe transactions, timely support You in emergency situations;
(12) Perform other activities related to the provision, operation and management of BSL of Your products and services and/or to develop, enhance and enhance the offering of products and services of BSL to You in general; and other purposes that BSL deems appropriate from time to time.

(13) To ensure BSL’s legitimate business purposes in case BSL deems necessary, including but not limited to the exchange of information with our partners, service providers;
(14) To enter data, to check the completeness and accuracy of the data You provide to BSL and/or the information BSL enters into the system;
(15) To comply with agreements and contracts between BSL and other third parties;
(16) To fulfill reporting, financial, accounting and tax obligations;
(17) To perform audit, risk management and compliance purposes activities;
(18) To serve the requirements of the internal operations of BSL or its member units (including for the purposes of credit and risk management, system/network planning and development, audit and administration);
(19) To carry out transactions such as transferring, disposing, merging or buying, selling and transferring BSL’s assets;
(20) To provide agencies and organizations providing credit assessment services, credit information, credit scoring.

(21) To fulfill its obligations under the law, international treaties to which BSL must comply;
(22) To provide to competent state agencies as prescribed by law;
(23) To generate data, reports and statistics on the basis of requests of the State Bank of Vietnam or competent authorities as prescribed by law;
(24) To provide and exchange information between BSL and credit institutions, credit information organizations in accordance with the law.

(25) For risk assessment, trend analysis, statistics, planning, including statistical data processing, credit and anti-money laundering, to create and maintain credit scoring systems , evaluate and maintain data about Your credit history;
(26) To detect, prevent and investigate crimes, attacks or violations including fraud, money laundering, terrorism, financing of weapons of mass destruction, bribery, corruption or tax evasion.

(27) To protect or enforce BSL’s legitimate rights and interests, including the right to collect fees, recover and settle debts owed to BSL by the Customer/Personal Data Subject;
(28) To fulfill responsibilities to the community and society.

(29) In case the Personal Data is processed for purposes other than those mentioned above and not yet provided for by law, BSL will only do upon agreement with You or upon obtaining Your consent.

a. Depending on the purpose of Personal Data Processing, BSL or a third party authorized to process data for BSL may apply appropriate processing methods including but not limited to automatic, manual or other methods in accordance with the provisions of law and BSL from time to time.
b. If the party to whom the Personal Data is disclosed is located overseas, the Personal Data may be sent to another country including countries with more restrictive Personal Data protection legislation than Vietnam. When providing/transferring Personal Data overseas (including but not limited to using cyberspace, equipment, electronic means or other means to transfer Personal Data out of the territory of Vietnam), BSL will require the third party receiving to ensure the safety and security of the Personal Data provided/transferred. BSL is committed to fully complying with regulations and compliance requirements of Vietnamese law to protect the safety of Personal Data.

(1) Parent Banks (including the Joint Stock Commercial Bank for Investment and Development of Vietnam, Sumitomo Mitsui Trust Bank and our other capital contributors – hereinafter collectively referred to as the “Mother Bank”); or subsidiaries/affiliated companies/agents/partners of the Parent Bank;

(2) Authorities having competence to request for providing information such as tax authorities, commercial arbitration, courts, procuracies, security or investigative agencies, judgment enforcement, or any other authority required by law to enforce liability from BSL;
(3) Any person, authority or regulatory body or third party to whom BSL is authorized or required to disclose pursuant to any country’s regulation or under any other contract or commitment between BSL and third parties.

(4) Units with the function of providing credit information and credit assessment services; credit scoring units; credit rating agencies; insurance company; insurance brokerage company; and other credit service providers;
(5) Vietnam National Credit Information Center (CIC), a licensed credit information institution, or any agency or organization established by the State Bank of Vietnam or any other any other authority over the BSL.
(6) The provider of credit checking, AML/CTF, KYC, PEP, fraud prevention and other crime detection services to which BSL is obligated to comply.

(7) Any contractor, service provider, consultant or other party cooperating with BSL (including its leaders, managers, employees); organizations/individuals who are sellers, suppliers, partners, agents including but not limited to companies providing support services for BSL’s business activities such as: organizations that provide administrative services, correspondence, telemarketing, direct sales, call centers, business processes, travel, visas, knowledge management, human resource management, data processing, information technology, computing, payments, debt collection, credit reference and other background checks, market research, data modeling, redemption, record storage and management, data entry, prescreening and verification, legal, website or social media, telecommunications, texting or emailing, networking, telephoning, infrastructure and technology support, workforce management, risk reporting, credit decisions, information security, maintenance of software and licenses, data centers, conversations and conferences, consulting services, payment intermediary services, switching and/or other services related to, or to support support, for the operation of BSL’s business;
(8) Business partners, related partners that cooperate with BSL to develop, provide or are involved in the development and provision of products and services of BSL.

(9) Any person acting on behalf of the Personal Data Subject (payee, beneficiary, designee in connection with the account, intermediaries, confirming banks, correspondent banks, etc.);
(10) Any person notified, authorized by the Personal Data Subject to be authorized to provide transaction information on behalf of the Personal Data Subject.

(11) Any credit institution, foreign bank branch and agent, financial institution, trader, intermediary in connection with any product or service provided by BSL to You.

(12) Other stakeholders that BSL deems necessary to meet and protect the legitimate rights and interests of the Personal Data Subject;
(13) Personal Data Subject’s, Your or BSL’s advisors including accountants, auditors, attorneys, financial advisors;
(14) Parties to the transaction of buying or selling debt and assets of BSL;
(15) Any person or entity intending to pay any outstanding amount under any of Your contract(s)/transaction(s) with BSL;
(16) Other Personal Data Processing parties carried out upon Your consent.

a. BSL may begin processing Personal Data pursuant to this Notice as soon as we receive the Personal Data from You and will retain it for as long as is necessary to fulfill the purposes for which the Data was collected, subject to the respective legal regulations. The reasonable period for retention of Personal Data includes:
(1) The period required by law on the protection of Personal Data;
(2) Other longer periods of time as we deem necessary. For example: To serve the settlement of complaints, lawsuits, investigations according to internal procedures or as prescribed by law.
b. After the retention period, BSL may destroy, delete or take any appropriate action in relation to Personal Data in any reasonable, practicable and appropriate manner that we understand to be permitted by law. We will not be obligated to return or destroy Personal Data if it is unreasonable or impossible.

(1) The right to know;
(2) The right to consent;
(3) The right of access (including viewing, rectifying or requesting rectification of Personal Data);
(4) The Right to withdraw consent;
(5) The right to delete data;
(6) The right to obtain restriction on processing;
(7) The right to provide data;
(8) The right to object to processing
(9) The right to file complaints, denunciations and lawsuits;
(10) The right to claim damage;
(11) The right to self-protection.
BSL will process Your requests in accordance with the law and consider Your legitimate interests. However, in case You withdraw your consent, request for data deletion and/or exercise other relevant rights above in respect of any or all Personal Data, the ability of BSL to provide/maintain our products and services to You may be effected. Then, depending on the nature of your request, BSL may consider and decide not to continue providing BSL’s products and services to You. Actions taken by You under this provision shall be deemed to be a unilateral termination on Your part of any relationship between You and BSL, and may completely lead to a breach of Your obligations or contractual commitments between You and BSL. Accordingly, BSL will not be liable to You for any loss incurred. At the same time, BSL reserves the rights and legal remedies of BSL in such cases.