CUSTOMER PRIVACY POLICY

1. General Terms

1.1. This Personal Data Protection Policy (“Policy”) is issued by Tam Sơn International Joint Stock Company, the owner and operator of the website tamsonvn.com (hereinafter referred to as “Tam Sơn” or “We”), and applies to all activities of Tam Sơn relating to tamsonvn.com regarding the protection of Personal Data of all customers and/or users of tamsonvn.com (collectively referred to as “Customer”).

1.2. This Policy is an integral part of the terms and conditions of use of Tam Sơn, as well as any agreements, transactions, service registrations, or other arrangements entered into between Customer and Tam Sơn.

1.3. By registering an account or using any product, service, or accessing any website or application operated by Tam Sơn, Customer acknowledges that they have read, understood, and agreed to all terms in this Policy and voluntarily consents (collectively referred to as “Consent”) to the collection, use, disclosure, storage, transfer, and/or processing of their Personal Data by Tam Sơn. This includes, without limitation, information collected before, during, and after Customer’s acceptance of this Policy, as described herein.

1.4. By giving Consent, Customer is deemed to have been fully informed of all terms in this Policy, including but not limited to: Tam Sơn’s right to process both basic and sensitive Personal Data; and Tam Sơn’s right to share Personal Data with third parties for the Purposes specified in this Policy. Customer also agrees that Tam Sơn may continue to collect their Personal Data for the purposes outlined herein without requiring further notification or consent from Customer. Tam Sơn shall ensure compliance with applicable laws when collecting information and processing data.

1.5. When providing the Personal Data of any third party (including but not limited to spouses, children, parents, guardians, friends, beneficiaries, authorized persons, partners, guarantors, emergency contacts, legal representatives, shareholders, or any other individuals related to Customer), Customer affirms that they have obtained lawful consent from such third party for Tam Sơn to process their data in accordance with this Policy. Customer agrees that Tam Sơn has no obligation to verify the legality of such consent and bears no responsibility if Customer fails to comply with this provision.

1.6. Tam Sơn is committed to the following principles when processing Personal Data:

a) Respecting and striving to protect the privacy, confidentiality, and security of Customer’s Personal Data, and ensuring compliance with Vietnamese laws, this Policy, and all contract, agreements, or other documents made with Customer;
b) Processing Personal Data for specific, clear, lawful purposes within the scope of this Policy and in accordance with Vietnamese laws;
c) Not collecting or processing the Personal Data of individuals under 16 years old. Any online order or account creation involving such individuals must be done with assistance from a parent or guardian. Parents/guardians who provide data for children between 7 and 16 years old are deemed to have lawful grounds and provide automatic consent on the child’s behalf for Tam Sơn to process the data under this Policy. Tam Sơn is not liable for any issues resulting from Customer non-compliance with this requirement;
d) Depending on its role in each situation, Tam Sơn may act as (i) a Personal Data controller; (ii) a Personal Data processor; or (iii) both a Personal Data controller and processor, and will fulfill its corresponding its right and obligations in accordance with applicable laws.

2. Types of Customer’s Personal Data Collected by Tam Sơn

To fulfill customer requests and deliver the best possible shopping experience, Tam Sơn may need to and/or be required to collect, store, control, use, and process Customers’ Personal Data (collectively referred to as “Personal Data”), including the following:

2.1. Basic Personal Data, including:

a) Identification information: Full legal name, other names (if any); date of birth; gender; nationality; mailing/shipping address; email address; phone number; national ID number, personal ID number, passport number, tax ID, driver’s license number, vehicle registration number, social insurance number, health insurance number; occupation, place of employment; marital status; and information about related persons, which may include but not limited to family members;
b) Bank account information and tax data;
c) Photographic and video data: Including surveillance recordings from Tam Sơn’s premises (if applicable);
d) “Tam Sơn Elite Club” loyalty program account information: Username and password;
e) Behavioral and transaction history: Shopping history at Tam Sơn stores; order details; product records; services purchased or reviewed; size/fit preferences and alterations;
f) Automatically collected data when using Tam Sơn websites, apps, or communication tools: device type, operating system, browser type and settings, IP address, language preferences, access date/time, web and app usage statistics, search queries, user login details, and location data, etc;
g) Marketing data: Advertising preferences, cookies, clickstream data, browsing history, responses to direct marketing, and opt-out choices, etc.;
h) Other data tied to or identifying an individual, not listed above, or legally classified as sensitive and requiring specific protection measures.

2.2. Sensitive Personal Data, including:

a) Political or religious beliefs;
b) Health-related information, such as reactions to Tam Sơn products, health conditions as recorded in medical documentation, excluding blood type information;
c) Racial or ethnic origin, genetic information, and unique physical/biometric characteristics;
d) Criminal record data collected by law enforcement; financial customer information from credit institutions, foreign bank branches, licensed intermediaries, and other authorized organizations;
e) Location data identifying an individual’s whereabouts via location services;

2.3. Other Personal Data provided by Customer when registering or using Tam Sơn’s services, or generated in the course of using Tam Sơn’s products and services.

3. Personal Data Processing Activities and Methods of Collection

Personal Data processing activities refer to one or more activities performed on a Customer’s Personal Data, such as: collection, recording, analysis, verification, storage, modification, disclosure, combination, access, retrieval, revocation, encryption, decryption, duplication, sharing, transmission, provision, transfer, deletion, destruction, or any other similar actions.

3.1. Tam Sơn may collect Customer’s Personal Data either directly or indirectly during the provision of any products or services. Data may come from, but is not limited to, the following sources:

3.1.1. Directly from Customer: Tam Sơn may collect Personal Data directly through Customer interactions such as consultations, transactions, service provision, or other activities where information is voluntarily shared.
3.1.2. Customer communications: Tam Sơn may collect data through various channels of communication, including but not limited to: in-person meetings, telephone calls, emails, postal correspondence, and electronic forms; as well as customer surveys, feedback forms, or complaint submissions. Information may also be obtained from registration forms and other documents related to Tam Sơn’s services and products;
3.1.3. Tam Sơn’s websites: When Customers access the Tam Sơn official website (https://tamsonvn.com) or other websites managed by Tam Sơn for its brands, such as: Sandro: https://sandro.com.vn, Maje: https://maje.com.vn, Hanoia: https://hanoia.com, ADLV: https://acmedelavie.com.vn, Okaidi Obabi: https://okaidi.vn, Front Row: https://front-row.com (collectively referred to as ”Website”), or when using any features or resources available on or through these Websites. When Customer accesses the Website, Tam Sơn may collect information about Customer’s device and browser (such as device type, operating system, browser information, IP address, language settings, time of connection to the electronic page, and other technical communication information), all or part of which may constitute Personal Data.
3.1.4. From interactions or automatic data collection technologies: Tam Sơn may collect customer’s Personal Data and related parties’s data automatically through Customer’s connection with Tam Sơn, such as cookies, plugins, third-party social media connectors, or other technologies capable of tracking or capturing Personal Data on such devices or electronic pages (e.g. Facebook, YouTube, TikTok, Instagram, Shopee, Tiki, Lazada, and others).
3.1.5. From other means: Tam Sơn may collect Personal Data when the Customer interacts with Tam Sơn through any other means; through surveillance footage recorded from cameras at Tam Sơn stores and business premises (if applicable);
3.1.6. From third parties, including but not limited to:
- a) When Customer interacts with third-party content or advertisements on Tam Sơn’s Website, Tam Sơn may receive Customer’s Personal Data from the relevant third party, in accordance with that third party’s applicable and lawful privacy policy;
- b) When Customer selects direct payment services to Tam Sơn or makes payments via the Website, Tam Sơn may receive Customer’s Personal Data from the respective payment service providers for the purpose of processing such services;
- c) Tam Sơn may receive Customer’s Personal Data from Tam Sơn’s service providers, partners, or consultants, including but not limited to: survey providers, social media marketing agencies, direct marketing partners, fraud prevention services, data aggregation services, infrastructure and IT service providers, and other third parties involved in Tam Sơn’s business operations;
- d) In order to fulfill its legal obligations, Tam Sơn may receive Customer’s Personal Data from law enforcement agencies or competent government authorities in accordance with applicable laws.
- e) From public sources (such as telephone directories, advertisement materials, publicly available online data, etc.).
- f) From other sources where Customer has given consent for sharing/providing Personal Data, or from sources that are required or permitted by law to share such data.

Whenever Personal Data is collected from third parties as mentioned above, Tam Sơn understands and assumes that these third parties have already obtained Customer’s valid consent for: (i) providing Customer’s Personal Data to Tam Sơn, and (ii) allowing Tam Sơn to process such data for the Purposes stated in this Policy. If Customer does not consent, Tam Sơn will not provide the Customer’s Personal Data to any third party. Tam Sơn shall not be held liable for any misuse or inappropriate processing of Customer’s Personal Data by third parties under their respective policies.

The cases stipulated in this Article are not intended to be exhaustive but rather illustrate common scenarios in which a Customer’s Personal Data may be collected. Through the methods mentioned above, Customer’s information will be collected by and/or sent to Tam Sơn and used for the purposes, duration, and in accordance with the provisions set forth below.

4. Purposes of Personal Data Processing

Tam Sơn may collect, store, use, and process Customers’ Personal Data for the purpose of providing the best possible customer experience (collectively referred to as “Purpose”), including but not limited to the following:

4.1. Provide products, services, and programs to Customers:

a) Deliver products, services, and programs to Customers and fulfill contractual obligations between Tam Sơn and Customer;
b) Personalize Customer experience with Tam Sơn; to provide offers and customer services tailored to Customers and related persons whose information has been lawfully provided by Customer; to manage events Customer has registered for and/or participated in;
c) Send Customers information relevant to their transactions and needs, in compliance with applicable direct marketing laws; or conduct promotional campaigns, gift redemption, prize delivery, and distribution of giveaways;
d) Support and take care of Customers, and enhance service quality;
e) Identify and resolve Customer issues promptly; to investigate and address inquiries, requests for clarification, and complaints from Customers;
f) Notify Customers of any changes to policies or promotions related to products and services provided by Tam Sơn.

4.2. Better understand Customer needs and improve product and service quality:

a) Deliver behavior-based or interest-based online advertising; to customize the content displayed on websites, applications, devices, and according to Customer preferences;
b) Monitor and enhance the Customer’s shopping experience; monitor product and service quality; improve and minimize product defects;
c) Assess service usage history and Customer engagement to improve product and service offerings, and to run loyalty and customer engagement programs that provide greater value to Customers;
d) Use and analyze Customer information to develop, deliver, and continuously enhance Tam Sơn’s products, services, and programs to better meet Customer expectations;
e) Provide Customer data to Tam Sơn’s service providers/partners in accordance with the terms of this Policy, for the purpose of fulfilling Customer-related services;
f) Conduct other related activities in connection with the delivery, operation, and management of Tam Sơn’s products and services and/or to improve, enhance, and improve the delivery of Tam Sơn’s products and services to Customers in general; and for other purposes Tam Sơn deems appropriate from time to time;

4.3. Verify the identity of Customer.

4.4. Process the transactions of purchases and payments made through Tam Sơn’s website.

4.5. Risk management, information security, and system safety:

a) Identify, verify, and maintain accurate Customer identification records;
b) Support Customer and update information when registering for or using products/services provided by Tam Sơn or its partners;
c) Ensure the confidentiality of Customer’s Personal Data and protect Tam Sơn’s systems and Customer’s Personal Data from unauthorized access;

4.6. Legal compliance and enforcement:

a) Establish or exercise, or defend Tam Sơn’s legal rights or claims;
b) Comply with Tam Sơn’s internal policies, applicable laws, industry standards, procedures, and any rules, regulations, guidelines, directives, or requirements issued by competent authorities in accordance with applicable laws.
c) Detect and prevent fraud, identity theft, and other illegal activities.
d) Take enforcement actions against acts that may constitute legal violations.
e) Comply with court rulings or legal obligations imposed by similar competent authorities on Tam Sơn.

4.7. For any other purposes as required or permitted by applicable laws, regulations, guidelines, and/or requests from competent authorities;

4.8. For other purposes as will be notified to Customer at the time of collecting Personal Data or before initiating the relevant processing, or as otherwise required or permitted by applicable laws.

5. Customer Rights and Obligations Regarding Personal Data

5.1. As the data subject, Customer has the following rights:

a) Right to be informed: Customer has the right to be informed about the processing of their Personal Data, unless otherwise provided by law;
b) Right of access: Customer has the right to access all information relating to themselves, including personal information used by Tam Sơn;
c) Right to rectification: Customer has the right to correct any inaccurate or incomplete basic information relating to themselves. However, Customers are responsible for verifying their own information, and Tam Sơn shall not be liable for any issues arising from incorrect information, whether on purpose or unintentional.
d) Right to restrict processing: Customer may request that the processing of their Personal Data be restricted without requiring the deletion of the data, in accordance with conditions stipulated by applicable laws.
e) Right to withdraw consent: If the processing of Customer’s Personal Data is based on prior consent, Customer may withdraw such consent at any time. However, such withdrawal shall not affect the legality of data processing previously carried out based on consent. In case of withdrawal of consent, Tam Sơn may be unable to provide full and quality services as requested if the withdrawn information directly impacts service provision or quality.
f) Right to lodge a complaint: Customer has the full right to lodge a complaint if Tam Sơn is found to have used their personal information for purposes other than those stated. Tam Sơn commits to investigating and taking responsibility for any damages Customer may suffer in such cases.
g) Other rights of the data subject as stipulated by law.

5.2. Within the limits permitted by law, Customers may exercise their rights through their personal account on Tam Sơn’s Website or by visiting any Tam Sơn store or business location within Tam Sơn’s store network for support, or be sending information and requests to Tam Sơn using the contact details provided in the “Contact Information” section below. We are committed to responding to and addressing Customer requests within 72 working hours from the time the request is received. Tam Sơn commits to fulfilling lawful and valid Customer requests within the time frame provided by applicable law.

Please note that any request to exercise rights must include at least the following information: (i) the Customer’s contact information; (ii) data subject right(s) the Customer wishes to exercise and the scope of relevant Personal Data; (iii) reasons for exercising such right(s); and (iv) relevant information or documentation supporting such rights.

Tam Sơn reserves the right to request additional information from Customer to verify the validity of the request or to decline the request if (i) the request does not comply with the above requirements; or (ii) Customer fails to provide sufficient information to validate the request.

5.3. Request to delete or remove Customer’s Personal Data

5.3.1. In the event that Customer withdraws their consent for data processing of Personal Data and/or requests the deletion/remove of Personal Data and/or exercises other related rights with respect to any or all of their Personal Data, Tam Sơn may consider and decide not to continue providing products or services to Customer due to the inability to ensure quality standards/quality of products or services as assessed by Tam Sơn, or because certain collection of Customer’s Personal Data is legally required for providing such products or services.
5.3.2. If Tam Sơn decides to discontinue providing products or services to Customer, such actions by Customer will be deemed a unilateral termination of any relationship with Tam Sơn, which may result in a breach of obligations or commitments under contracts or agreements between Customer and Tam Sơn (if any). In such cases, Tam Sơn reserves all legal rights and remedies.
5.3.3. Once a deletion request is submitted and verified as valid, Customer’s Personal Data will be removed from our internal information systems and CRM within 72 working hours. Please note that once removal is successful, Customer will no longer be entitled to any benefits from Tam Sơn (including but not limited to: discounts, customer service priority, etc.).
5.3.4. Tam Sơn shall not be liable for any loss or damage to Customer (if any), and Tam Sơn’s legal rights shall be expressly reserved with respect to such limitation, restriction, suspension, cancellation, prevention, or prohibition. Customers should note that due to the nature of Tam Sơn’s operations, Tam Sơn may be required by law to retain Customer information in certain cases, in which case Tam Sơn cannot fulfill Customer’s request for data deletion if it would result in a legal violation.

5.4. Customer is obligated to:

a) Comply with applicable laws, this Policy, and Tam Sơn’s regulations and guidelines regarding Personal Data processing.
b) Provide complete, truthful, and accurate Personal Data and other information as required by Tam Sơn when registering and using products/services, and promptly update changes. Tam Sơn will protect Personal Data based on registered information; thus, Tam Sơn is not liable for any issues or limitations caused by inaccurate data.
c) Notify Tam Sơn promptly of any changes to their Personal Data. If no notification is provided, Customer will bear responsibility for any risks or losses resulting from errors, misuse, or fraud arising from Customer’s failure to provide accurate, complete, and timely updated information, including financial damage or costs due to incorrect or inconsistent information.
d) Cooperate with Tam Sơn, competent authorities, or third parties in the event of issues affecting their Personal Data.
e) Proactively protect their Personal Data and implement protective measures to safeguard their Personal Data during the use of Tam Sơn’s products/services; immediately notify Tam Sơn upon detecting any errors, inaccuracies, or suspected violations of their Personal Data.
f) Take full responsibility for any information, data, or consent provided online; and for any Personal Data leakage due to their own actions.
g) Regularly update and review Tam Sơn’s Personal Data Protection Policy, as notified to Customer from time to time or published on Tam Sơn’s Website. Act in accordance with instructions to confirm full/partial/conditional consent or non-consent to the Purposes of Personal Data processing notified to Customer from time to time.
h) Respect and protect the Personal Data of others.
i) Fulfill other obligations related to Personal Data protection as required by law.

6. Provision of Personal Data

6.1. Tam Sơn will not sell, trade, lease (whether temporarily or permanently) Customer’s personal information, nor will it share Customer’s Personal Data with any third party in violation of this Policy or without Customer’s consent as required by applicable law.

6.2. In order to fulfill the Purposes and data processing activities in accordance with this Policy, Customer agrees to allow Tam Sơn to share/disclose their Personal Data, or the Personal Data of third parties related to Customer, in the following cases:

a) Tam Sơn internal staff: Employees and workers of Tam Sơn who perform tasks on behalf of Tam Sơn, within the scope allowed under this Policy and any agreements entered into between Customer and Tam Sơn;
b) Affiliated entities: Tam Sơn’s parent company, subsidiaries, and affiliated companies under the Openasia Group, as determined from time to time;
c) Tam Sơn’s service providers and partners, including:
- – Contractors, agents, service providers, and other third parties hired by Tam Sơn to support or supplement Tam Sơn’s business operations, including but not limited to logistics, IT, payment, marketing, market research, training, legal, and audit services, etc.;
- – Organizations and individuals involved in the development, maintenance, provision, or improvement of products and services for Customer;
- – Business partners or associated entities working with Tam Sơn to develop or provide Tam Sơn’s products and services to Customer.
- – In cases of proposed or completed sales, mergers, or transfers of all or part of Tam Sơn’s business or assets (including reorganizations, dissolution, liquidation, restructuring, or changes in control), Tam Sơn may provide Customer’s Personal Data to potential buyers or sellers, or their representatives, provided that Tam Sơn has first taken reasonable and lawful steps to ensure the safety and confidentiality of Customer’s Personal Data;
d) Brand owners: The owners of the brands of products purchased by Customer from Tam Sơn, including foreign-based organizations, for the purpose of data storage and global customer service.
e) Authorities: Competent State authorities in Vietnam, or any regulatory authority, organization, or individual to whom Tam Sơn is permitted or required to disclose such data by law or relevant regulations;
f) Other third parties, including:
- – Any individual or organization involved in the enforcement or fulfillment of any rights or obligations under the agreement(s) between Customer and Tam Sơn;
- – Any parties authorized or consented to by Customer, or where Tam Sơn has a legal basis to share Customer’s Personal Data.

6.3. Tam Sơn is committed to only sharing or co-processing Personal Data when necessary to fulfill the purposes outlined in this Policy or as required by law. Any organization or individual receiving Customer’s Personal Data must comply with the provisions of this Policy and relevant data protection regulations.

6.4. Notwithstanding the provisions above, in order to fulfill any of the purposes outlined in this Policy, Tam Sơn may transfer or authorize a third party to transfer Customer’s Personal Data outside the territory of Vietnam. However, such cross-border data transfers will only be carried out in accordance with applicable regulations.

7. Storage of Personal Data

7.1. Customer’s Personal Data will be stored, managed, and protected by Tam Sơn in accordance with its internal policies. Tam Sơn will take reasonable measures to protect Customer’s Personal Data in accordance with this Policy and applicable laws during the data retention process.

7.2. Tam Sơn retains Customer’s Personal Data for the period necessary to fulfill its obligations to Customer and as required by this Policy and Vietnamese law, unless a longer retention period is required or permitted by Customer or by law. Subject to applicable laws, Tam Sơn may store Customer’s Personal Data within Vietnam or abroad, including cloud-based solutions. Data will be retained for as long as necessary to fulfill the purposes set out in this Policy, in relevant contracts, agreements, or other documents established with Customer, unless a longer period is required or permitted under the law.

7.3. Tam Sơn will cease storage and management of Customer’s Personal Data or remove any association with Customer’s Personal Data as soon as there is reasonable evidence that Tam Sơn is storing and managing such data in a manner inconsistent with the original purposes and it is no longer necessary for any other legal or commercial purpose.

8. Amendments to the Personal Data Protection Policy

8.1. When necessary, Tam Sơn may amend, supplement, or adjust the provisions of this Policy from time to time, ensuring that any amendments or supplements comply with applicable regulations. Any changes or updates to this Policy will be published on Tam Sơn’s Website and/or communicated to Customer via other communication channels deemed appropriate by Tam Sơn.

8.2. To the extent permitted by laws, Customer’s continued use of Tam Sơn’s products and services after the notice period of such amendments shall constitute Customer’s acceptance of the updated contents of this Policy.

9. Potential Unintended Consequences or Damages

9.1. Tam Sơn implements various information security technologies such as firewalls and encryption to safeguard and prevent unauthorized access, use, or disclosure of Customer’s Personal Data. However, no data can be absolutely guaranteed to be secure in cyberspace. Therefore, we cannot commit to absolute security of Customer’s Personal Data, including but not limited to the following situations:

9.2. Hardware or software errors during data processing that result in the loss of Customer data;

9.3. Security breaches beyond our control, such as hacking incidents causing data leakage.

9.4. Tam Sơn advises Customers to protect login credentials, OTP codes, and avoid sharing such information with others.

9.5. Customer should be aware that whenever Personal Data is disclosed or made public, such data may be collected and used for purposes beyond both Customer’s and our control.

9.6. We recommend Customers safeguard their personal devices (phones, tablets, personal computers) during use and log out of their accounts when not in use.

9.7. In the event that the data server is attacked, resulting in the loss or leakage of Customer’s Personal Data, Tam Sơn will notify relevant authorities for timely investigation and resolution, and notify Customer in accordance with applicable laws.

9.8. The internet is not a secure environment, and we cannot guarantee that Customer Data transmitted via the internet will always be confidential. When transmitting Personal Data online, Customer should only access Tam Sơn’s websites, apps, or devices via secure systems. Customers are responsible for maintaining the confidentiality and security of their access credentials for each website, application, or device.

10. Contact Information

To exercise Customers’ rights, or for inquiries or discussions regarding Personal Data or this Policy, Customers may contact Tam Sơn through the following channels:

– Call Tam Sơn’s Customer Service at: 096 240 6664 (Monday – Friday | 9:00 – 17:00);
– Email: [email protected]
– Visit any official retail store in Tam Sơn’s distribution system; or
– Visit Tam Sơn’s head offices:
- + Hanoi: Floor 3, No. 21, Alley 2, Lê Văn Hưu Street, Phạm Đình Hổ Ward, Hai Bà Trưng District, Hanoi
- + Ho Chi Minh City: Room 1601, Harbour View Building, 35 Nguyễn Huệ Street, Bến Nghé Ward, District 1, Ho Chi Minh City

We welcome all feedback, inquiries, and suggestions from Customers regarding this Policy and the protection of their Personal Data.

11. General Provisions

11.1. This Policy takes effect on July 16, 2025, and may be amended from time to time in accordance with Section 8 of this Policy. Such changes will take effect as prescribed by law.

11.2. This Policy also serves as the Notification of Personal Data Processing and Notification of Disclosure to Third Parties, in accordance with current legal regulations.