Personal Data Protection Policy

The Personal Data Protection Policy for Customers of Galaxy Holdings/ Galaxy Telecom (hereinafter referred to as the “Policy”) aims to inform Customers about their Personal Data processed by Galaxy Holdings/ Galaxy Telecom, the purposes of processing, the methods of processing, the storage period, and the rights and obligations of Customers regarding their Personal Data in accordance with Vietnamese law on Personal Data protection. This Policy also provides recommendations to help Customers raise awareness about Personal Data protection.

This Policy is an inseparable part of the Mobile Information Service Provision and Use Contract, the Subscriber Information Registration Confirmation for Mobile Information Service, the General Terms and Conditions for Mobile Information Service, and other contracts and general terms that Customers have entered into with Galaxy Holdings/ Galaxy Telecom. This Policy applies to all product and service provision activities of Galaxy Holdings/ Galaxy Telecom and applies across all platforms interacting with Customers, including in the digital environment.

By ticking the box "I have read and accepted" or "I agree with the Policy, Terms of Use of Galaxy Holdings/ Galaxy Telecom” or by signing a contract, entering into a model contract, general transaction conditions with Galaxy Holdings/ Galaxy Telecom, or by continuing to register, log in, use the website/app of Galaxy Holdings/ Galaxy Telecom or use products and services of Galaxy Holdings/ Galaxy Telecom without any complaints, Customers confirm that they have carefully read, understood, and fully accepted the entire content of this Policy completely voluntarily, without deception or coercion.

Article 1. Interpretation of Terms and Abbreviations

Within the scope of this Policy, the following terms are understood and interpreted as follows:
Galaxy Holdings is Galaxy Digital Holdings Co., Ltd.
Galaxy Telecom is Galaxy Telecom Co., Ltd.
Customer is:
- An individual or legal representative of an individual who uses and/or is interested in the products and services of Galaxy Holdings/ Galaxy Telecom/ Parent Company/ Subsidiaries/ Member Companies of Galaxy Holdings;
- An individual or legal representative of an individual who has accessed and/or registered an account on the websites/apps owned by Galaxy Holdings/ Galaxy Telecom/ Parent Company/ Subsidiaries/ Member Companies of Galaxy Holdings/ Galaxy Telecom.
Products and services of Galaxy Holdings/ Galaxy Telecom are:
- Products and services directly researched, developed, and provided to Customers by Galaxy Holdings/ Galaxy Telecom;
- Products and services provided to Customers by Galaxy Holdings/ Galaxy Telecom in cooperation with partners.
Personal Data is information in the form of symbols, text, numbers, images, sounds, or similar forms associated with a specific person or helping to identify a specific person.
Personal Data Processing is one or more activities impacting personal data, such as: collection, recording, analysis, confirmation, storage, editing, publicizing, disclosure, combination, access, retrieval, revocation, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction of personal data or other related actions.

Article 2. Types of Personal Data Processed

The Customer's Personal Data processed by Galaxy Holdings/ Galaxy Telecom (hereinafter referred to as “Personal Data”) includes the following information and may vary depending on the type of product or service, and the Customer's interaction with Galaxy Holdings/ Galaxy Telecom (Galaxy Holdings/ Galaxy Telecom will specifically notify of any changes (if any) and obtain the data subject's consent for such changes):
2.1.1. Basic Personal Data
a) Full name, middle name, and birth name, other names (if any);
b) Date, month, year of birth; date, month, year of death or disappearance;
c) Gender;
d) Place of birth, place of birth registration, permanent residence, temporary residence, current address, hometown, contact address;
đ) Nationality;
e) Individual's image, including images provided by Customers when registering for services, images uploaded by Customers on Galaxy Holdings/ Galaxy Telecom's applications (apps)/websites during service use;
g) Phone number, ID card number, personal identification number, passport number, driver's license number, vehicle license plate number, personal tax code number, social insurance number, health insurance card number;
h) Marital status;
i)  Family relationship information (parents, children);
k) Information about an individual's digital account;
l) Data on consumption behavior reflecting activities, activity history on the cyber environment of Customers when using products and services of Galaxy Holdings/ Galaxy Telecom (online behavior; frequency, average call duration, messages, customer care calls; device type; operating system; 4G/5G device user ratio; time, data volume of domestic network usage, international roaming; international roaming packages; forms and amounts of phone top-ups and usage; service payment time; prepaid or postpaid SIM; value-added service subscription rate; short/long data package subscription rate);
m) Customer's telecommunications credit score: presented as a score, which is the result of Galaxy Holdings/ Galaxy Telecom's processing and analysis of Customer data using Galaxy Holdings/ Galaxy Telecom products and services;
n) Information through mobile device usage: phone configuration, application version information on the phone, customer's phone book;
o) Other information associated with a specific person or helping to identify a specific person not falling under the provisions of Clause 2.1.2 of this Article.
2.1.2. Sensitive Personal Data
a) Data on criminal offenses and criminal acts collected and stored by law enforcement agencies;
b) Customer information of credit institutions, foreign bank branches, payment intermediary service providers, and other permitted organizations, including: customer identification information as stipulated by law, account information, deposit information, asset deposit information, transaction information, information about organizations and individuals acting as guarantors at credit institutions, bank branches, payment intermediary service providers;
c) Data on an individual's location identified via positioning services;
d) Political views, religious views;
đ) Health status and private life recorded in medical records, excluding blood type information;
e) Information related to racial origin, ethnic origin;
g) Information about genetic characteristics inherited or acquired by an individual;
h) Information about physical attributes, unique biological characteristics of an individual;
i) Information about sexual life, sexual orientation of an individual;
k) Other personal data stipulated by law as specific and requiring necessary security measures.
2.2. The information and data of Customers mentioned in this Article by Galaxy Holdings/ Galaxy Telecom include basic personal data and sensitive personal data. Sensitive personal data are data related to the privacy of Customers. Galaxy Holdings/ Galaxy Telecom commits to protecting the sensitive personal data of Customers in accordance with legal provisions.

Article 3. Purpose of Personal Data Processing

The Personal Data according to Article 2 above may be processed by Galaxy Holdings/ Galaxy Telecom, the data processor of Galaxy Holdings/ Galaxy Telecom, and third parties authorized to process data by Galaxy Holdings/ Galaxy Telecom for one or more of the following purposes:
3.1. Providing products, goods, and services to Customers and exercising the rights and obligations of Galaxy Holdings/ Galaxy Telecom according to contracts/agreements and legal provisions, including but not limited to:
(a) Verifying the accuracy and completeness of information provided by Customers; identifying or authenticating the identity of Customers and performing Customer authentication procedures as regulated;
(b) Processing the registration for using Galaxy Holdings/ Galaxy Telecom products and services. Providing, activating, or verifying products, goods, and services requested by Customers through request forms/contracts/agreements or via Galaxy Holdings/ Galaxy Telecom's transaction channels or other Customer requests arising during the process of searching, accessing, purchasing, registering, or using products, goods, and services;
(c) Serving business management activities; operating, exploiting, optimizing the quality of network, mobile services, Internet, and other products and services provided by Galaxy Holdings/ Galaxy Telecom and/or partners; resolving network incidents; providing, improving the quality of products, goods, and services;
(d) Authenticating and executing payment transactions; reconciling charges, paying charges; exchanging and providing information related to telecommunications service users with other telecommunications businesses and service providers for the purpose of calculating charges, invoicing, and preventing evasion of contractual obligations within the scope permitted by law; protecting or enforcing Galaxy Holdings/ Galaxy Telecom's legitimate interests such as the right to collect fees and debts from Customers to Galaxy Holdings/ Galaxy Telecom; reconciling with Galaxy Holdings/ Galaxy Telecom's cooperative partners for the purpose of providing products, goods, and services to Customers;
(e) To identify, authenticate, and update Customer information; to evaluate, determine, appraise, consider, and approve the provision or continued provision of products, goods, and services to Customers. Galaxy Holdings/ Galaxy Telecom may use scoring methods, assigning hot billing thresholds, checking Customer's history of using Galaxy Holdings/ Galaxy Telecom products and services to evaluate and manage credit risk, ensure payment capability for payment obligations and other related obligations throughout the process of Galaxy Holdings/ Galaxy Telecom providing products and services to Customers;
(f) For the purpose of contacting and notifying Customers;
(g) Advertising, marketing, providing products based on Customer's interests and service usage habits: Galaxy Holdings/ Galaxy Telecom may use Personal Data to provide, advertise, and market to Customers about Galaxy Holdings/ Galaxy Telecom's products, services, promotional programs, research, surveys, news, updates, events, contests with prizes, awarding related prizes, relevant advertisements and content about Galaxy Holdings/ Galaxy Telecom's products and services and/or those of companies within Galaxy Holdings/ Galaxy Telecom's ecosystem and/or those of partners cooperating with Galaxy Holdings/ Galaxy Telecom.
(h) Activating features that personalize Customer experience, such as identifying interests, favorite application lists, and interest information, recommending products, services;
(i) Performing necessary internal activities to provide Services, including troubleshooting software errors and operational issues, conducting data analysis, testing and research, monitoring and analyzing usage trends and activities;
(j) Allowing Our partners to manage and allocate resources to provide Services.
(k) Exercising Customer's rights related to Personal Data in accordance with legal provisions, agreements between Customers and Galaxy Holdings/ Galaxy Telecom and/or partners of Galaxy Holdings/ Galaxy Telecom;
(l) Fulfilling obligations with relevant agencies, organizations, and individuals according to contracts/agreements or legal provisions;
(m) Publicizing Customer's Personal Data in accordance with legal provisions;
(n) Fulfilling obligations regarding inspection, examination, statistics, reporting, finance, accounting, and taxes;
(o) Performing data security operations; ensuring the security of Galaxy Holdings/ Galaxy Telecom's information systems such as backup, disaster recovery, monitoring, resource optimization, and customer Personal Data protection;
(p) Preventing crime, fraud or minimizing threats to the life, health of others and public interest: Galaxy Holdings/ Galaxy Telecom may use Customer's personal information to prevent and detect crime, fraud, abuse to protect Customers, Galaxy Holdings/ Galaxy Telecom and related entities;
(q) Sending notification messages, communications, advocacy, support related to the National Humanitarian Information Portal and at the request of state management agencies;
(r) Detecting, preventing, investigating, preventing illegal acts on the cyber environment at the request of competent state agencies and legal provisions, including but not limited to: spam messages, spam emails, spam calls, fraudulent messages, fraudulent emails, fraudulent calls;
(s) Detecting, preventing, investigating, preventing fraudulent acts, deception, attacks, intrusions, illegal appropriation, criminal acts and other illegal acts;
(t) Performing activities for auditing, risk management, anti-money laundering, counter-terrorism financing, and sanction compliance; Preparing financial reports, activity reports, dossiers for bidding or participating in bidding or other related reports as required by law;
(u) In cases of national defense, national security, social order and safety emergencies, major disasters, dangerous epidemics; when there is a risk of threatening security, national defense but not yet at the level of declaring a state of emergency; preventing and combating riots, terrorism, crime and legal violations according to legal provisions;
(v) Serving the activities of state agencies as stipulated by specialized laws.
3.2. Supporting Customers when purchasing, registering to use, and using products, goods, and services provided by Galaxy Holdings/ Galaxy Telecom/ Parent Company/ Subsidiaries/ Member Companies of Galaxy Holdings and/or partners according to contracts/agreements and legal provisions, including:
(a) Updating and processing information when Customers purchase, register to use, and use Products, goods, and services provided by Galaxy Holdings/ Galaxy Telecom/ Parent Company/ Subsidiaries/ Member Companies of Galaxy Holdings and/or partners of Galaxy Holdings/ Galaxy Telecom;
(b) Customer care, receiving and resolving Customer inquiries and complaints regarding products, goods, and services;
(c) Using and transferring to partners Personal Data, problematic information, incidents, and error reports reflected by Customers to identify and fix issues with Products, goods, and services; repairing Customer's equipment; performing other activities for customer care and support.
3.3. Improving the quality of Products, goods, and services provided by Galaxy Holdings/ Galaxy Telecom and/or partners to Customers:
(a) Providing information that Customers have requested or Galaxy Holdings/ Galaxy Telecom believes Customers may find useful, including information about Products, goods, and services as stipulated by law;
(b) Improving technology, interface of electronic information pages, wapsites, social networks, applications, platforms, tools... to ensure convenience for Customers;
(c) Managing Customer accounts and loyalty programs;
(d) Storing information, market research, analysis, statistics, and other internal management activities to enhance Customer experience;
(e) Reporting, statistical analysis, and internal data analysis to research, build, develop, manage, measure, provide, and improve products, goods, and services as well as operate Galaxy Holdings/ Galaxy Telecom's business;
(f) Developing marketing campaigns for products, goods, and services and determining how Galaxy Holdings/ Galaxy Telecom and/or partners can personalize such products, goods, and services;
(g) Developing and providing new products, goods, and services personalized to the Customer's needs and actual conditions with effective measurement methods;
(h) Introducing and providing promotional programs for products, goods, and services, incentives, promotions by Galaxy Holdings/ Galaxy Telecom and by Galaxy Holdings/ Galaxy Telecom in cooperation with partners;
(i) Evaluating the ability to purchase and use products, goods, and services through telecommunications rating scores or other Customer rating scores/indices to best support the provision of products, goods, and services to Customers;
(j) Conducting marketing services, advertising, introducing products, goods, and services suitable to Customer needs or which Galaxy Holdings/ Galaxy Telecom and/or partners believe Customers are interested in, according to the following content, form, and frequency:
- Content: Introducing information about products, goods, services, and promotions provided by Galaxy Holdings/ Galaxy Telecom and partners of Galaxy Holdings/ Galaxy Telecom;
- Method: Via advertising messages (SMS, USSD, MMS…), IVR calls, notifications on Galaxy Holdings/ Galaxy Telecom's transaction channels or other methods as stipulated by law;
- Form: Directly sent to Customers via electronic devices, means or other forms in accordance with legal provisions;
- Frequency: As per advertising law.
3.4. Conducting research, analysis, testing, and development activities including but not limited to data analysis, surveys, product and Service development and/or creating customer profiles, to analyze how Customers, analyze the market, conduct activities on Galaxy Holdings/ Galaxy Telecom's platforms, improve Services to enhance Customer experience, develop new features, products and Services and facilitate financial and insurance solutions while protecting data, improving and enhancing safety, security, and confidentiality;
3.5. Organizing trade promotion and introduction.
(a) Sending Customers, by methods consistent with legal provisions, notices, updates, documents, advertising and promotional information, greetings, invitations, participation management, and materials related to the Services, Us and our sponsors, partners, and advertisers of products, Services, events or promotional programs.
(b) We may communicate marketing via postal mail, telephone calls, short message services, online messaging services, text notifications, and email.
(c) Customers may unsubscribe from receiving marketing and promotional information by following Our instructions at the time.
3.6. Conducting market research services, public opinion polling, brokerage.
Galaxy Holdings/ Galaxy Telecom does not engage in unauthorized buying and selling of Personal Data.

Article 4. Method of Personal Data Processing

4.1 Galaxy Holdings/ Galaxy Telecom may collect Customer's personal data in the following ways and forms:
(a) Direct collection from Customers:
i. From product and service provision activities: when Customers provide information or information arises during the registration and use of products, services, utilities that Galaxy Holdings/ Galaxy Telecom provides through direct transaction channels, service provision platforms;
ii. From Galaxy Holdings/ Galaxy Telecom's websites: Galaxy Holdings/ Galaxy Telecom may collect Customer data when Customers access any Galaxy Holdings/ Galaxy Telecom website using any features or resources available on or through these websites;
iii. From Galaxy Holdings/ Galaxy Telecom's mobile applications: Galaxy Holdings/ Galaxy Telecom may collect Customer data when Customers download or use mobile applications. These applications may record data such as app usage statistics, device type, operating system, app settings, IP address, language settings, date and time of connection to the app, location data and other technical communication information… and accordingly, all or some of this data may constitute Customer's personal data;
iv. From exchanges, communications, and interactions with Customers: Galaxy Holdings/ Galaxy Telecom may collect Customer data when Customers contact or interact (such as in person, via mail, phone, online, electronic communication, social networks, surveys or any other means);
v. From audio and video recording devices attached to Galaxy Holdings/ Galaxy Telecom's equipment or placed at stores, business locations within Galaxy Holdings/ Galaxy Telecom's network or other locations where Customers interact with Galaxy Holdings/ Galaxy Telecom. Please note that Galaxy Holdings/ Galaxy Telecom may be recording audio and video when Customers communicate and interact with Galaxy Holdings/ Galaxy Telecom for the purposes of verifying Customer and Customer's transactions; and/or for security purposes, safety of Customer's transactions and assets, as well as those of Galaxy Holdings/ Galaxy Telecom.
(b) Collection from third parties or other information sources:
i. Galaxy Holdings/ Galaxy Telecom may also collect Customer data by accessing personal information stored by third parties or other information storage sources, such as information authentication service providers, goods/services providers, payment service providers, electronic information pages, social networks... Through this, Galaxy Holdings/ Galaxy Telecom may receive controlled information from these third parties or information storage sources, and Customers agree that Galaxy Holdings/ Galaxy Telecom may collect, store, process, and use this information;
ii. To comply with its obligations under current law, Galaxy Holdings/ Galaxy Telecom may also receive Customer data from competent authorities.
4.2. Galaxy Holdings/ Galaxy Telecom may process Customer's personal data in the following ways and forms:
(a) Depending on the purpose of processing Customer's personal data in each specific case, Galaxy Holdings/ Galaxy Telecom may apply appropriate processing methods including but not limited to automatic personal data processing methods (through cookies and/or other related technologies), non-automatic or other methods ensuring data protection requirements.
(b) During data processing, Galaxy Holdings/ Galaxy Telecom applies one or more activities impacting personal data such as: collection, recording, analysis, confirmation, storage, editing, publicizing, combining, accessing, retrieving, revoking, encrypting, decrypting, copying, sharing, transmitting, providing, transferring, deleting, destroying data, personal data or other related actions.
(c) Galaxy Holdings/ Galaxy Telecom may directly or through a personal data processor process Customer's data in accordance with current legal provisions.
(d) To achieve the purposes of processing Customer's personal data, Galaxy Holdings/ Galaxy Telecom may transfer Customer's personal data abroad and/or to locations outside the territory of Vietnam. Galaxy Holdings/ Galaxy Telecom will comply with the requirements of Vietnamese law, the law of the country/territory to which the data is transferred, and apply necessary measures to protect Customer's personal data.

Article 5. Start and End Time of Data Processing

5.1 Start time of data processing
From the time the Purposes specified in Article 3 of this Policy arise.
5.2. End time of data processing
Galaxy Holdings/ Galaxy Telecom ceases processing Personal Data when the Purpose specified in this Policy has been completed, unless otherwise stipulated by law or Customer withdraws consent to Personal Data processing or when a competent state agency requests it in writing.
5.3. Galaxy Holdings/ Galaxy Telecom may need to store Customer's Personal Data even after the contract/agreement between Customer and Galaxy Holdings/ Galaxy Telecom has terminated to fulfill Galaxy Holdings/ Galaxy Telecom's legal obligations according to legal provisions and/or requests from competent state agencies.

Article 6. Sharing Personal Data

Customers agree to share their Personal Data with the following organizations and individuals to achieve the Purposes specified in the Policy, specifically:
6.1. Parent company, subsidiaries of Galaxy Holdings/ Galaxy Telecom, affiliated companies, member companies, branches of Galaxy Holdings/ Galaxy Telecom, affiliated companies of the Parent Company, subsidiaries of Galaxy Holdings/ Galaxy Telecom and other related entities of Galaxy Holdings/ Galaxy Telecom;
6.2. Third-party service providers or partners in business cooperation contracts (with or without profit sharing): Galaxy Holdings/ Galaxy Telecom uses and/or cooperates with other companies and individuals to perform certain tasks and programs such as cooperating in providing content services, value-added services, services provided on telecommunications networks and the internet, advertising programs, promotions for Customers, market research, product analysis and development, strategic consulting, and billing collection services. These third-party service providers and/or partners have the right to access, collect, use, and process Customer's Personal Data within the scope permitted by Galaxy Holdings/ Galaxy Telecom to perform their functions and must comply with legal provisions on Personal Data protection as data processors;
6.3. Other partners at the request or confirmation of the Customer (including but not limited to electronic means on Galaxy Holdings/ Galaxy Telecom's Websites/Applications or in writing). For example, when a Customer desires a service through a Galaxy Holdings partner such as using banking services, airline services, promotional programs provided by a Galaxy Holdings/ Galaxy Telecom partner, the Customer hereby agrees that Galaxy Holdings/ Galaxy Telecom may share the Customer's Personal Data with such partners. The Customer also agrees that Personal Data shared with Galaxy Holdings/ Galaxy Telecom's partners may be transferred to parties in connection with the service used by the Customer. Galaxy Holdings/ Galaxy Telecom's partners include partners integrated with Galaxy Holdings/ Galaxy Telecom's applications/websites or Galaxy Holdings/ Galaxy Telecom's applications/websites integrated with the partner's system, transportation service partners, financial partners, or other business partners with whom Galaxy Holdings/ Galaxy Telecom cooperates to provide promotional programs, other services;
6.4. Exchanging, providing, and sharing Personal Data with third parties such as advisors, experts, agents, or suppliers, subcontractors of Galaxy Holdings/ Galaxy Telecom to implement products, work, and services consistent with the Purpose of use.
6.5. Exchanging and providing Personal Data to suppliers, consultants, marketing partners, research companies, and other service providers or business partners, including: personal information authentication partners, payment processing and support departments; anti-money laundering services; server service providers, information technology services, cloud storage providers; advertising partners and advertising platform providers; data analytics providers; research partners, including those who conduct surveys or research projects in cooperation with Galaxy Holdings/ Galaxy Telecom; insurance, financial, banking, airline, technology, telecommunications partners.
6.6. Business restructuring: During business development, Galaxy Holdings/ Galaxy Telecom may sell or acquire businesses or restructure businesses in accordance with legal provisions and production and business needs. In such transactions, Personal Data will be transferred, and the transferee must still comply with the provisions of this Policy;
6.7. Galaxy Holdings/ Galaxy Telecom is allowed to disclose Personal Data at the request of law, at the request of competent state management agencies;
6.8. Galaxy Holdings/ Galaxy Telecom is allowed to disclose Personal Data to other telecommunications enterprises to facilitate billing, invoicing, and preventing Customer from evading contractual obligations.

Article 7. Customer Rights

Right to know and Right to consent
Customers have the right to know about the processing activities of their personal data, unless otherwise stipulated by law. Except for cases specified in Article 13 of this Policy, Customers have the right to agree or disagree with the terms and conditions of this Policy in the manner instructed by Galaxy Holdings/ Galaxy Telecom on channels and means such as SMS messages, calls, ticks on websites/applications or by contacting Galaxy Holdings/ Galaxy Telecom's customer care hotline in accordance with legal provisions. Galaxy Holdings/ Galaxy Telecom only processes Personal Data when Customer's consent has been obtained.
7.2. Right to access and request Personal Data provision
Customers have the right to access Galaxy Holdings/ Galaxy Telecom's applications/websites and/or directly contact Galaxy Holdings/ Galaxy Telecom to view, edit, and extract their Personal Data, unless otherwise stipulated by law.
In case Customers cannot self-access to view, edit, or extract, or encounter difficulties in accessing to view, edit, or extract Personal Data, Customers should contact Galaxy Holdings/ Galaxy Telecom for assistance.
7.3. Right to rectify
Customers have the right to rectify their Personal Data provided that this rectification does not violate legal provisions. In case Customers cannot self-rectify or encounter difficulties in rectifying Personal Data, Customers may contact Galaxy Holdings/ Galaxy Telecom for assistance.
7.4. Right to object, restrict, withdraw consent to data processing
a) Customers have the right to object, request restriction of Personal Data processing, or withdraw consent to Customer's Personal Data processing. However, objecting to, restricting, or withdrawing consent to Customer's Personal Data processing may result in Galaxy Holdings/ Galaxy Telecom being unable to provide Products and services to Customers, which means Galaxy Holdings/ Galaxy Telecom may unilaterally terminate the contract without compensation to Customers due to changes in contract performance conditions (unless due to Galaxy Holdings/ Galaxy Telecom's fault). Therefore, Galaxy Holdings/ Galaxy Telecom recommends Customers carefully consider before objecting to, restricting, or withdrawing consent to Customer's Personal Data processing.
b) In case Customers wish to limit receiving marketing and promotional content from Galaxy Holdings/ Galaxy Telecom and wish to withdraw their previous consent (if any) and/or object to the continued use of their personal information for the purposes specified in Article 3 of this Policy, Customers should follow the instructions of Galaxy Holdings/ Galaxy Telecom at the time Galaxy Holdings/ Galaxy Telecom collects Personal Data or contact Galaxy Holdings/ Galaxy Telecom using the information provided in this Policy. If Customers do not wish to receive notifications from Galaxy Holdings/ Galaxy Telecom's application, please adjust the notification settings in their application or device.
7.5. Right to erase Personal Data
Customers have the right to request Galaxy Holdings/ Galaxy Telecom to erase their Personal Data provided that Customer's request complies with legal provisions. However, Customer's request to erase Personal Data may result in Galaxy Holdings/ Galaxy Telecom being unable to provide Products and services to Customers, which means Galaxy Holdings/ Galaxy Telecom may unilaterally terminate the contract without compensation to Customers due to changes in contract performance conditions (unless due to Galaxy Holdings/ Galaxy Telecom's fault). Therefore, Galaxy Holdings/ Galaxy Telecom recommends Customers carefully consider before requesting Galaxy Holdings/ Galaxy Telecom to erase Personal Data.
7.6. Right to complain, denounce, sue
Customers have the right to complain, denounce, or sue in accordance with legal provisions.
7.7. Right to claim damages
Customers have the right to claim damages in accordance with legal provisions when there is a violation of regulations on personal data protection, unless otherwise agreed by the parties or stipulated by law.
7.8. Right to self-protection
Customers have the right to self-protect in accordance with the Civil Code, other relevant laws, and Decree 13/2023/ND-CP on personal data protection (and any amending or replacing documents), or to request competent agencies or organizations to implement civil rights protection methods as stipulated in Article 11 of the Civil Code.

Article 8. Customer Obligations

Customers are responsible for protecting their Personal Data as follows:
8.1. Actively implement measures to protect, manage, and safely use accounts and personal technological devices (including devices such as smartphones, computers, tablets, laptops, and other devices) by logging out after use, setting a strong password, and keeping their login information and password confidential. The aforementioned measures for safe account and mobile device use help prevent unauthorized access to Customer accounts. Galaxy Holdings/ Galaxy Telecom is exempted from liability for Customer's damages in cases where Customer's password is exposed/lost, stolen, leading to unauthorized account access, or any activity on Customer's account used on a lost or misplaced mobile device leading to unauthorized service use, or if Galaxy Holdings/ Galaxy Telecom's system is illegally compromised by a third party despite Galaxy Holdings/ Galaxy Telecom having implemented all necessary measures to protect the system (unless due to Galaxy Holdings/ Galaxy Telecom's fault);
8.2. Having accepted all terms and conditions of this Policy, Customers are responsible for providing complete and accurate Personal Data as requested by Galaxy Holdings/ Galaxy Telecom and are responsible for immediately notifying Galaxy Holdings/ Galaxy Telecom upon detecting any violation of personal data protection regulations;
8.3. Customers are responsible for respecting the Personal Data of other data subjects and for complying with legal provisions on Personal Data protection, participating in preventing and combating violations of Personal Data protection regulations.

Article 9. Personal Data Storage

9.1. Customer's Personal Data stored by Galaxy Holdings/ Galaxy Telecom will be kept confidential. Galaxy Holdings/ Galaxy Telecom is responsible for implementing measures to protect Customer's Personal Data in accordance with legal provisions.
9.2. Location of Personal Data Storage
Within the scope permitted by law, Galaxy Holdings/ Galaxy Telecom may store Customer's Personal Data in Vietnam and abroad, including on cloud computing storage solutions. Galaxy Holdings/ Galaxy Telecom applies data security standards consistent with current legal provisions. The transfer of personal data abroad must comply with the provisions of Article 25 of Decree 13/2023/ND-CP (as amended, supplemented, or replaced from time to time) and other legal provisions.
9.3. Personal Data Storage Period
Galaxy Holdings/ Galaxy Telecom only stores Customer's Personal Data to fulfill the Purposes specified in this Policy. However, if current law provides otherwise regarding the Personal Data storage period, Galaxy Holdings/ Galaxy Telecom has the obligation to comply with legal provisions.

Article 10. Obligations of Galaxy Holdings/ Galaxy Telecom

10.1. Customer's Personal Data is committed to be confidential in accordance with legal provisions and Galaxy Holdings/ Galaxy Telecom's Personal Data Protection Policy.
10.2. Galaxy Holdings/ Galaxy Telecom strives to ensure Customer's Personal Data is protected from violations of personal data protection regulations and to prevent loss, destruction, or damage due to incidents, using technical measures. Galaxy Holdings/ Galaxy Telecom maintains its commitment to Personal Data confidentiality by applying physical, electronic, and management measures to protect Personal Data, including:
a) The official website servers of Galaxy Holdings/ Galaxy Telecom and information systems containing Galaxy Holdings/ Galaxy Telecom's personal data are protected by security measures and technologies such as firewalls, encryption, unauthorized intrusion prevention; issuing human control measures, building inspection, evaluation, and review processes to prevent violations of personal data protection regulations.
b) Galaxy Holdings/ Galaxy Telecom will take all necessary measures to ensure that Customer's Personal Data is processed correctly for the announced Purpose. Galaxy Holdings/ Galaxy Telecom will always comply with legal requirements related to Personal Data storage.
10.3. Fulfilling Customer's requests related to Customer's personal data, provided that Customer's requests comply with legal provisions.
10.4. Other obligations as stipulated by law and this Policy.

Article 11. Potential Unintended Consequences and Damages

11.1. Galaxy Holdings/ Galaxy Telecom uses various information security measures and technologies to protect Customer's Personal Data from unintended use or sharing. Galaxy Holdings/ Galaxy Telecom commits to maximum confidentiality of Customer's Personal Data. Some potential unintended consequences and damages include:
a) Hardware and software errors during Personal Data processing causing unintended impacts (errors, damage, loss) to Customer's Personal Data;
b) Security vulnerabilities beyond Galaxy Holdings/ Galaxy Telecom's control, system attacks by hackers leading to disclosure of Customer's Personal Data;
c) Customer's self-disclosure of Personal Data due to: carelessness or fraud; accessing websites/downloading applications containing malicious software; voluntarily sharing information with others.
11.2. Galaxy Holdings/ Galaxy Telecom advises Customers to strictly adhere to the responsibilities for Personal Data protection as stipulated in Article 8 of this Policy and by law.
In case the data storage server is attacked by hackers leading to the loss of Customer's Personal Data or Customer's self-disclosure of Personal Data as stipulated in Points b and c, Clause 1 of this Article, Galaxy Holdings/ Galaxy Telecom is responsible for (i) notifying the incident to the competent authority for timely investigation and handling and informing the Customer; (ii) Coordinating with the competent authority to resolve and ensure legal rights for the customer.

Article 12. Internet Advertising and Third Parties

Galaxy Holdings/ Galaxy Telecom's websites/applications may include third-party advertisements and links to other websites/applications. Third-party advertising partners may collect information about Customers when Customers interact with their content, advertisements, or services. All access and use of third-party links or websites are not governed by this Policy, but instead by the privacy policies of those third parties.

Article 13. Personal Data Processing Without Data Subject's Consent

Galaxy Holdings/ Galaxy Telecom may process Personal Data without the data subject's consent in the following cases:
13.1. In an emergency, it is necessary to immediately process relevant Personal Data to protect the life or health of the data subject or another person;
13.2. Publicizing Personal Data as stipulated by law;
13.3. Data processing by a competent state agency in cases of national defense, national security, social order and safety emergencies, major disasters, dangerous epidemics; when there is a risk of threatening security, national defense but not yet at the level of declaring a state of emergency; preventing and combating riots, terrorism, crime and legal violations as stipulated by law;
13.4. To fulfill the data subject's contractual obligations with Galaxy Holdings/ Galaxy Telecom as stipulated by law;
13.5. Serving the activities of state agencies as stipulated by specialized laws.

Article 14. Contact Information

In case Customers have any questions about this Policy or wish to exercise their rights related to Personal Data, please contact Galaxy Holdings/ Galaxy Telecom using the methods and information below:
14.1. Contact the hotline using the information on Galaxy Holdings/ Galaxy Telecom's official websites/applications at the relevant time.
14.2. Send official correspondence to the following addresses:…………….
14.3. Contact directly at Galaxy Holdings/ Galaxy Telecom's transaction points nationwide.
14.4. Other contact methods such as Livechat (online chat software), contact via Galaxy Holdings/ Galaxy Telecom's official fanpage (electronic information page), customer care email provided to Customers at all times./.