Privacy Protection

PRIVACY POLICY

1. Introduction

This Privacy Policy applies to the personal data of individuals (hereinafter referred as “you” or “your”) with dealings or contact with HAMADEN VIET NAM (hereinafter referred as “Company”, “we”, “us” or “our”) through any means.

This Privacy Notice will inform you of the basis on which we may collect, use, disclose, transfer and/or process (collectively “process”) your personal data in accordance with the Law Personal Data Protection and all applicable personal data protection regulations as well as your rights with regards to your personal data processed by the Company or third parties.

2. Collection of Personal Data

Depending on your relationship with us, the Company may collect various types of your personal data, including the following:

• Your identity data (e.g. name, identification card number, passport number, driving license number, date of birth, age, gender, nationality, marital status, etc.)
• Your contact details (e.g. residential address, home phone number and mobile number, personal email address, Facebook ID, etc.)
• Your business contact information (e.g. title, position and name of company, etc.)
• Your electronic identification data where required for the purpose of dealing with us (e.g. login, access right, passwords, IP address, online identifiers/cookies, system activity logs, access and connection times, image recording or sound such as CCTV recordings, photographs or other images of you, voice recordings or meeting recordings, etc.)
• Sensitive personal data as described by Decree 13 (e.g. race, ethnic origin, religion, medical record, commission of misconduct, crimes, allegations thereof and/or convictions (criminal records), bank ac details, financial information, etc.)
• Other data falling within the definition of “personal data” in Law (hereinafter collectively referred to as “Personal Data”)

3. Source of Personal Data

We may collect your Personal Data one or more of the following sources:

• Information that you voluntarily provide to us (i) directly, such as via websites, telephonic communications, emails, facsimiles, Company questionnaire or survey, or any other written or verbal communications or documents provided to us prior to and during the course of our dealings with you; or (ii) via a third party whom you have duly authorized to disclose your personal data to us after this Privacy Policy is provided and relevant consent is obtained;
• Any other sources via which collection and use of your personal data without consent is permitted or required by the Decree 13 or other regulations; or
• The personal data is publicly available or publicly accessible.

4. Purpose of Collection and Use of Personal Data

We may collect, use or disclose your Personal Data for any of the following purposes (hereinafter collectively referred to as the “Purposes”):

• Performing obligations in the course of or in connection with our general business dealings with you;
• Implementing and monitoring activities at our facilities, including compliance with applicable policies as well as health and safety rules in place;
• Providing our products and/or services to you;
• Communicating with you during the term of our contract, relationship, or business dealings with you, and contacting you in case of emergency;
• Conducting credit and other status checks at the time of application for our services, business dealings and periodically during the tenure of the services or business dealings with you;
• Customizing and improving services and/or related products for customers’ use and satisfaction;
• Conducting marketing activities;
• Researching and statistical analysing.

The Company will process your Personal Data for the Purposes on your consent only when the Company cannot rely on other legal bases, e.g. legal obligation, contractual obligation, legitimate interest, or vital interest.

5. Disclosure or Transfer of Personal Data

We may disclose or transfer your Personal Data to the following categories of recipients:

(a) Denso Group Companies

We may disclose or transfer your Personal Data to Denso group companies (including Denso Corporation in Japan and its subsidiaries, both local and international) for internal administrative purposes and uses consistent with the Purposes.

(b) Third Parties

We may disclose or transfer your Personal Data to third parties such as legal or other professional advisors, business partners, service providers and/or any organizations engaged by the HAMADEN VIET NAM to perform functions for and in respect of the Purposes.

(c) Regulators or Law Enforcement Agencies

We may share your Personal Data with regulatory bodies or law enforcement agencies where disclosure is required under applicable laws.

6. Cross-Border Transfers

We may need to disclose or transfer your Personal Data to the Hamaden Viet Nam and/or the Third Parties located outside Vietnam or need to use various systems to process your Personal Data, including systems hosted in servers outside of Vietnam, where the personal data protection standards may be inferior to those under the Decree 13, for and in respect of the Purposes. If we do so, we will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under Law

7. Provision of Consent

The consent that you provide for the collection, use, disclosure, transfer, and processing of your Personal Data will remain valid until such time it is being withdrawn by you in writing.

If you elect not to provide any of the categories of Personal Data we may request you, or if you choose not to provide your consent for the Company to process your personal data for any of the Purposes, depending on the nature and scope of the request or your lack of consent, we may not be able to provide you with the services that you want, process your application, establish any business dealings with you, or undertake to achieve the Purposes.

Please note that withdrawal of your consent will not affect any processing of your Personal Data for which you have already provided consent, and which has already taken place prior to such withdrawal

8. Accuracy and Retention of Personal Data

The Company generally rely on Personal Data provided by you (or your authorized representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing us in writing or via email at the contact details provided below.

We may retain your Personal Data for as long as it is necessary to fulfil the Purposes for which they were collected, or as required or permitted by applicable laws.

We will cease to retain your Personal Data, or remove the means by which the Personal Data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the Purposes for which the Personal Data were collected, and is no longer necessary for legal or business purposes as required or permitted by the applicable laws.

During the retention period, the Company is committed to ensuring the protection and security of your Personal Data in accordance with the Law and other applicable laws. We have put in place appropriate administrative, physical and technical measures accordingly to safeguard your Personal Data unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

9. Individual Rights

You have the rights regarding your Personal Data as provided in Appendix of this Privacy Policy. You may exercise the rights by giving notice to the Companys representative (using the contact information at Clause 10 below).

10. Contact Information

Data Protection Officer (DPO): Ms Ngo Thi Phuong

Tel: +84-221 3589 388 (ext: 3001)

Email: phuong.ngo.thi.a3i@ap.denso.com

11. Effective Date

This Policy is effective Dec 1st, 2024.

The Company reserves the right to update this Privacy Policy time to time.

HAMADEN VIET NAM CO., LTD

                                                                                           Gerenal Director

                                                                                         (Đã ký)

                                                                                           Katsushi Hirao

APPENDIX: RIGHTS OF DATA SUBJECT

According to Law regulation , individuals have the following rights:

• To be informed of the processing of their Personal Data
• To give or refuse consent (subject to legal basis)
• To request access, copies, transfer, or restriction of processing
• To withdraw consent
• To request deletion of Personal Data
• To object to processing, especially for marketing purposes
• To request correction or updates
• To request protection of civil rights

You also have the right to:

• File complaints with competent authorities
• Initiate legal action
• Claim damages in case of violations

The Company commits to ensuring protection, security, and accuracy of your Personal Data in accordance with applicable laws.