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Legal

Privacy Policy

How NST collects, uses, stores and protects personal data, including image and biometric data.

Reference translation. This English version is provided for convenience only. In case of any discrepancy, the Vietnamese version prevails.

  1. PRIVACY PRINCIPLES

Personal data and information that the Customer consents to NST collecting and/or provides to NST in the course of registering for and using the Products shall be processed and kept confidential in accordance with the law and this Policy. The Customer hereby expressly agrees that it has carefully read, understood and agreed to, and is bound by, all of the provisions and content described in this Policy. Thereby, the Customer permits NST and NST Partners to use the Customer’s data to support NST in providing the Products to the Customer. In addition, the Customer agrees and acknowledges that the information set out in this Policy is equivalent in effect to a notification from NST to the Customer before NST processes personal data. Accordingly, NST is not required to take any further measure for the purpose of notifying the Customer of the processing of personal data.

NST shall collect, use, store and process the Customer’s personal data only in accordance with the relevant applicable laws, this Policy, and the Contract and other agreements between the Customer and NST. Where the Customer’s use of the Products gives rise to the collection and processing of personal data of third parties, the Customer represents and warrants that it has provided such third parties with complete information on the content of this Policy and has obtained the lawful consent of such third parties for NST to process the personal data for the purposes set out in this Policy. In addition, the Customer understands that NST will not be required to re-verify such consent. In the event of a breach of any of the provisions of this clause, the Customer undertakes and warrants that it shall bear sole legal liability arising therefrom and shall itself take charge of resolving the matter with the third parties and the relevant individuals/organisations, and agrees to compensate NST for all damage.

Depending on NST’s role in each specific case, NST is (i) a Personal Data Controller; (ii) a Personal Data Controller-Processor; or (iii) a Personal Data Processor under an agreement or contract with the Customer as the Personal Data Controller; NST shall exercise the corresponding powers and perform the corresponding obligations in accordance with applicable laws. NST wishes to note that the collection and processing of the Customer’s personal data is a necessary and sufficient condition for NST to be able to provide the Products to the Customer.

2. DEFINITIONS

“Policy” is the short form of this Personal Data Protection and Processing Policy, together with its amendments and supplements from time to time.

“Data Subject” means the person reflected by the Personal Data. Within the scope of this Policy, the Data Subject may be the Customer or another person whose Personal Data is collected and processed in the course of the Customer’s use of the Products.

Other terms used in this Policy shall be understood and interpreted in accordance with the Terms of Use and the applicable laws on personal data protection.

3. SCOPE OF APPLICATION

This Policy applies to:

Customers and partners using NST’s Products;

Individuals whose data is recorded by NST’s Products;

Customers accessing the NST Platform.

4. TYPES OF DATA PROCESSED

NST may process the types of Personal Data listed below, which may vary depending on the nature of the Products that the Customer wishes to use and on the Customer’s requirements from time to time, as follows:

4.1. Image and video data

Images from AI cameras;

Surveillance video;

Captured facial images.

4.2. Biometric data

Facial recognition data (face template);

Data used for identity authentication.

4.3. System data

Time and location of recording;

System access logs;

Device and connection information.

5. WHEN AND HOW NST COLLECTS DATA

NST may collect personal data in circumstances including but not limited to the following:

5.1. From the use of the system

When the camera system records images/video;

When the facial recognition software is in operation;

When data is generated from the operation of the system.

5.2. From customers and user organisations

When customers configure the system;

When data is entered into the platform;

When integrating APIs or third-party systems.

5.3. Automatic collection

System logs;

Access data;

Device and interaction information.

5.4. From third parties

Authorised partners;

Lawful or public data sources;

Integrated systems.

5.5. Cookies and similar technologies

NST may use cookies, local storage, session storage, technical logs or similar technologies on the website, applications and the NST Platform for the purposes of operation, security, recording access status, supporting the Customer and improving the quality of the Products.

Information that may be recorded through cookies or similar technologies includes: session identifiers, IP address, device type, browser, operating system, access time, pages or features used, error information, interaction information and other technical information necessary for operation, security and technical support.

NST uses cookies and similar technologies for the following purposes:

Maintaining the stable operation of the website, applications and the Platform;

Securing the system, preventing unauthorised access, and detecting technical errors or abusive behaviour;

Recording and analysing errors and improving the quality of the Products;

Remembering certain user choices, if any;

Receiving, handling and responding to the Customer’s support requests.

NST does not use cookies to sell Customer information, does not buy or sell personal data, and does not use cookies for the purposes of behavioural advertising, retargeting or sharing data with third parties for independent marketing purposes.

In certain cases, NST may embed or link to third-party support forms, including Google Forms, for the Customer to submit support request information. When the Customer accesses or fills in these forms, the third party providing the form may use cookies or similar technologies in accordance with its own policies. NST uses the information provided by the Customer through such forms only to receive, handle and respond to support requests or for purposes directly related to the Customer’s request.

The Customer may manage, block or delete cookies through the settings of the Customer’s browser or device. Blocking or deleting certain cookies may affect the browsing experience, the ability to remember choices, the operation of support forms or certain technical features of the website, applications and the NST Platform.

Session cookies may be deleted when the Customer closes the browser or ends the session. Certain cookies, technical logs or support data may be retained for the period necessary for the purposes of operation, security, technical support, resolving the Customer’s requests, complying with the law or protecting the lawful rights and interests of NST.

6. PURPOSES OF DATA PROCESSING

The Customer agrees to and permits the processing of Personal Data by NST for the following purposes:

Providing, operating and maintaining the Products;

Identity authentication and access control;

Ensuring security and safety;

Detecting and preventing fraudulent conduct or violations;

Aggregating, analysing, evaluating, researching, improving and enhancing the performance and quality of the Products.

7. SHARING OF PERSONAL DATA

NST may share data in the following cases:

At the request of competent state authorities;

As designated by the Customer;

With NST Partners, including but not limited to infrastructure providers (cloud, hosting), for the purpose of operating the system;

Other cases as provided for in the Contract and by law.

8. STORAGE OF PERSONAL DATA

  • Personal data is stored on the device (edge), on NST’s cloud system, on infrastructure managed by the Customer and .
  • Personal data is stored by the Customer according to the configuration set up by the Customer on the Products; and by NST through a data storage partner in Vietnam and in compliance with the provisions of Article 11 of this Policy. NST shall not be responsible if the Customer does not set up a storage configuration appropriate to the Customer’s purpose of use.

9. RIGHTS AND OBLIGATIONS OF DATA SUBJECTS

9.1. The rights of the Data Subject include:

  • To be informed of personal data processing activities;
  • To give or withhold consent to, and to request the withdrawal of consent to, the processing of personal data; to view, correct or request the correction of personal data;
  • To request the provision or deletion of personal data or the restriction of its processing; to submit objections to the processing of personal data;
  • To lodge complaints and denunciations, initiate lawsuits and claim compensation for damage in accordance with the law;
  • To request competent authorities, or the agencies, organisations and individuals involved in the processing of personal data, to implement measures and solutions to protect their personal data in accordance with the law.
  • The Customer may exercise the above rights directly on the NST Platform or by contacting NST using the contact information published in this Policy.
  • Before fulfilling the Customer’s request, NST may request evidence and complete relevant information to enable NST to locate the Personal Data under the Customer’s control and/or to authenticate the Customer. NST shall fulfil lawful and valid requests from the Customer within a reasonable period of time in accordance with the law.
  • NST shall receive, review and handle the Customer’s lawful and valid requests within a reasonable time limit in accordance with the law and NST’s internal procedures.

9.2. The obligations of the Data Subject include:

  • To protect their own personal data;
  • To respect and protect the personal data of others;
  • To provide their own personal data completely and accurately as required by law, under a contract or when consenting to the processing of their personal data;
  • To comply with the law on personal data protection and to participate in preventing and combating infringements of personal data.

9.3. When exercising their rights and performing their obligations, the Data Subject must fully comply with the following principles:

  • To act in accordance with the law; to comply with the obligations of the data subject under this Policy and the Contract. The exercise of the rights and performance of the obligations of a data subject must be for the purpose of protecting the lawful rights and interests of that data subject;
  • Not to cause difficulties for or obstruct the exercise of the legal rights and the performance of the legal obligations of personal data controllers, personal data controller-processors and personal data processors;
  • Not to infringe the lawful rights and interests of the State or of other agencies, organisations or individuals.
  1. BIOMETRIC DATA

Facial recognition data is sensitive data.

NST:

  • Does not exploit this data for its own purposes;
  • Processes it only at the request of the customer;
  • Applies a higher level of protection.

The Customer is responsible for:

  • Ensuring that valid consent has been obtained (if required);
  • Complying with the relevant legal regulations.
  1. UNDESIRABLE CONSEQUENCES AND DAMAGE THAT MAY OCCUR

10.1. NST applies internal policies, regulations and procedures in accordance with the law and makes its utmost efforts to implement security measures to protect Personal Data against unauthorised or unintended access, leakage, sharing, loss, use, exploitation, abuse, alteration, destruction or processing. However, notwithstanding NST’s utmost measures to protect personal data, in the course of the processing of personal data by NST or by authorised third parties, events or acts may still occur due to objective causes beyond NST’s reasonable control, which may lead to undesirable consequences and damage for the data subject, including but not limited to the following events:

  1. Force majeure events such as natural disasters, floods, earthquakes, fires or terrorist attacks resulting in failure of or damage to the hardware of the data storage and processing systems;
  2. Attacks aimed at unauthorised access to and appropriation of data stored on the system, or data leaks from security vulnerabilities beyond NST’s control, resulting in personal data being stolen or destroyed;
  3. Incidents involving NST’s systems or technical infrastructure, or arising from the fault of a Third Party authorised to process data;
  4. Hardware or software errors in the course of data processing resulting in the leakage or loss of the data subject’s data;
  5. The Data Subject, through their own fault, discloses their personal data due to: carelessness or being defrauded, accessing websites, or loading websites or applications containing malware, etc.
  6. The disclosure of personal data to other parties without the consent of the User may lead to the following possible undesirable consequences and damage: personal data being used for other purposes without the consent of the data subject, the data subject’s property being appropriated, or the honour and reputation of the data subject being infringed, etc. In addition, the destruction of the User’s personal data may cause the following possible consequences and damage: NST’s provision of services to the User being interrupted or rendered impossible, NST being unable to provide information to competent state authorities upon request as prescribed by law, etc.

In the event of an incident, NST shall provide notification within a reasonable time and coordinate with the Customer in handling the incident.

10.2. The Data Subject should be clearly aware that, whenever the Data Subject discloses and makes public their Personal Data, such data may be collected by others and used for purposes beyond the control of the Data Subject and NST.

10.3. Where the Data Subject disagrees with certain data processing purposes set out in this Policy by exercising the right to deletion, the right to request deletion or the right to withdraw consent, or by restricting or objecting to data processing, this may result in NST being unable to provide the Products to the Customer under the Contract. Depending on the case, the Data Subject may (a) be unable to continue using the Products; or (b) be subject to other restrictions, depending on the case.

  1. START TIME AND END TIME OF PERSONAL DATA PROCESSING

11.1. Personal Data shall be processed from the time NST receives the data collected in accordance with Article 5 of this Policy.

11.2. To the extent permitted by law, Personal Data shall be processed until NST’s data processing purposes set out in this Policy have been fulfilled.

11.3. NST may be required to retain certain types of Personal Data of the Data Subject even after the Contract has terminated, in order to perform NST’s legal obligations under the law and/or at the request of competent state authorities.

  1. AMENDMENTS TO THE POLICY

This Policy may be amended, supplemented or updated from time to time at NST’s discretion by posting the updated version on the NST Platform and notifying the Customer. The Customer’s continued access to or use of the Products, or the absence of an express written request to NST to withdraw consent or to cease using the Products, shall be deemed to constitute the Customer’s acceptance of all amendments, supplements and updates to this Policy as of the time the Terms of Use are amended, supplemented or updated.

  1. CONTACT INFORMATION

NATIONAL SECURITY TECHNOLOGY JOINT STOCK COMPANY (Công ty Cổ phần Công nghệ An ninh Quốc gia)

Head office: No. 5 Nguyễn Thị Duệ Street, Yên Hòa Ward, Hà Nội City, Vietnam

Website: https://nstgroup.vn/

Email: [email protected]

Hotline:

  1. EFFECTIVENESS

This Policy is attached to and forms an integral part of the Terms of Use.

Matters not provided for in this Policy shall be governed by the Terms of Use and the provisions of law.