1. What We Collect

We may collect your personal information in the course of providing VinFast Products to you. The collection of your personal information shall be made in accordance with this Privacy Policy where posted in connection with VinFast Products and as permitted by applicable data protection laws of relevant jurisdictions.

Here are the sources from which we gather your information:

• Information Given to Us: You may provide us with information about you in relation to VinFast Products.

• Automatic Information: Certain types of information are automatically obtained by us when you interact with VinFast Products.

• Other Sources of Information: We might receive information about you from other sources such as service suppliers, motor vehicle agencies, financial institutions, social media platforms, and public sources.

You will be informed if certain personal information is mandatory to be provided or if its is optional. If the mandatory information that is required is not provided, access to certain features of the VinFast Products may be impossible.

We may collect the following categories of your personal information:

• Information relating to your identity;

• Your image, voice, and other identifiers that are personal to you when you attend an event of VinFast or use VinFast’s Products;

• Identifiers and encrypted password;

• Payment data;

• Corporate and tax information;

• Your credit history;

• Commercial relationship data;

• Invoices data;

• Contact data;

• Newsletter registration data;

• Your interests declared via a form or deduced from the use of VinFast Products;

• Contacts and exchanges with us;

• Technical navigation and interaction data;

• Location data.

• Other personal data: information that you have provided concerning, for example, your date of birth, your education, your family and / or professional situation, as well as the composition of your household+

For more examples about the information collected, please refer to Section 14 of this Policy. We may combine these different categories of information we have about you.

2. How We Use

Your personal information may be used to administer, deliver, and improve VinFast Products. We may use personal information for the following purposes, amongst others:

• Operate, Provide VinFast Products: To administer, process and deliver VinFast Products and handle contracts related to VinFast Products, including without limitation registrations, subscriptions, loyalty programs, surveys, purchases, incentive programs and payments. The processing of this information is necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide VinFast Products, to respond to requests from you, or to provide customer support.

• Assess, Evaluate, and Improve VinFast Products: To assess the use, evaluate performance, fix errors, support and develop VinFast Products. The processing of this information is based on our legitimate interests in assessing, evaluating and improving VinFast Products.

• Recommendations and Personalization: To recommend VinFast Products that you may like, recognize your preferences, and personalize your experience with VinFast Products. The processing of this information is based on (i) our legitimate interests in providing you with personalized recommendations and experience, and (ii) your consent where required by applicable laws..

• Comply with Law: In certain cases, we have a legal obligation to collect, use, or retain your personal information or otherwise need to process certain types of personal information to ensure compliance with the law. The processing of this information is necessary for us to comply with relevant legal obligations or for our legitimate interests in ensuring and documenting compliance with applicable laws.

• Use your data in the context of our legitimate interest, or in the legitimate interest of the organization with which we have shared your data: When we have ensured that your personal data and your rights in relation to this data are protected, we can, for example, rely on this legal basis if we wish to use your personal data in order to:

• Understand and improve our products and services as well as our marketing strategy

• Measuring in particular the efficiency of our commercial operations and customer satisfaction

• Manage and improve our relationship with you as well as for administrative purposes

• Manage our satisfaction surveys and your responses in order to improve customer satisfaction and our products and services, in particular following a request for an appointment in a store or a VinFastVinFast repair center, a test of our vehicles or a vehicle reservation request

• Help you understand what information, products or services are likely to be of interest to you and to communicate or show you information, offers, online advertising for those products or services

• Personalize your experience of our products and services

• Ensure research and development of products and services

• Ensure the quality of vehicles, parts and services, in particular by carrying out studies of the After-Sales Service

• Contact You: To communicate with you in relation to VinFast Products through relevant channels such as email and chat and to answer your requests. This includes contacting you (or other necessary parties) to advise you of important safety-related information, or to notify first responders in the event of an accident involving VinFast Products. The processing of this information is necessary (i) for performing our contractual obligations, (ii) for our legitimate interests and (iii) complying with our relevant legal notification obligations.

• Marketing: To promote VinFast Products in accordance with the local laws. We may display interest-based ads for VinFast Products. The processing of this information is based on our legitimate interests in promoting VinFast Products, and (ii) your consent where required by applicable laws.

• Prevention of Fraud and Abuse and Credit Risks: To locate and handle fraud to protect our customers, ourselves, and others. We may also use scoring methods to assess and manage credit risks. The processing of this information (i) is necessary for complying with our relevant legal obligations relating to fraud prevention, and (ii) is based on our legitimate interests in preventing fraud and abuse and managing credit risks.

3. Collection and Use of Cookies

We may use cookies and other similar technologies and tools (collectively, “cookies”) for a variety of purposes.

Cookies are small files that our website asks your browser to save when you visit our website on your computer or mobile device. In particular, they make it possible to detect whether a link between your device and our website has already been established.

In principle, you can categorize cookies as follows:

• Essential cookies

• Marketing cookies

• Social Media cookies

• Analytical cookies

• Tracking cookies

Our website currently does not use cookies.

We however do use the tool “Google Fonts” - so-called web fonts for the uniform representation of fonts, which are provided by Google LLC, USA, and its affiliates (“Google”). When you call up a page, your browser loads the needed web fonts in their browser cache to correctly display texts and fonts. For this purpose, your browser connects to the servers of Google. This can also lead to a transmission of personal data to the servers of Google LLC. in the US. In this way, Google learns that our website was accessed via your IP address. The use of Google Fonts is in the interest of a uniform and appealing presentation of our online offers, and efficient use of fonts as well as a fast loading of fonts displayed to you as a visitor. This forms legitimate interest within the meaning of Art. 6 Paragraph 1 lit. f GDPR.

In case your browser does not support web fonts, a standard font is used by your computer. For more information on Google Fonts, see https://developers.google.com/fonts/faq and Google's privacy policy under https://www.google.com/policies/privacy/

4. When We Share and Who We Share With

Information about our customers is important to us and our business does not sell our customers’ personal information to others for monetary consideration. We share personal information only as described in this Privacy Policy. We may also share personal information with our affiliates, all of these companies are subject to this Privacy Policy or similar policies.

• Transactions Involving Third Parties: We make available to you services, software, and content provided by third parties for use on or through VinFast Products. You will know when a third party participates in a transaction with you and we may share information relevant to that transaction with that third party.

• Third-Party Service Providers: We employ and/or cooperate with other companies and individuals to perform certain functions on our behalf and carry out certain incentive programs, cross-sale programs, etc. Other examples may include: sending communications, processing payments, evaluating credit and compliance risks, interest-supporting program, analyzing data, providing marketing and sales support (including advertising and event management), managing customer relationship, and training. These third party providers have access to personal information needed to perform their roles, but we do not permit them to use it for other purposes. Further, we require them to adhere to the applicable data protection law.

• Restructuring, Business Transfers: As we continue to develop our business, we might restructure, sell or buy businesses or services in accordance with the laws. In such transactions, personal information, databases and right to use information may be transferred as business assets but the transferee remains subject to the Privacy Policy (or the individual consents otherwise). Also, in the event that VinFast or substantially all of its assets are acquired, your information will be one of the transferred assets. We may share personal informaiton with third parties are reasonably necessary to negotiate or complete a merger, acquisition, or sale of all or part of our assets.

• Protection of Us and Others: We may disclose account and other personal information when such disclosure is required by law, to enforce or apply our terms and other agreements, or to protect the rights, assets, or the safety of ourselves, our customers, or others. This may include releasing exchanging information to other organizations for fraud prevention and detection and credit and property risk reduction, or disclosing certain types of information in case we receive legally binding requests from public authorities.

• Your Choice: Other than as set out above, you will be notified when your personal information is shared with third parties, and you may be able to elect not to share the information.

5. Where We Store

VinFast has offices in in Vietnam, Europe, and some other countries and regions in the world. Depending on your use of VinFast Products, your personal information may be stored in or accessed from multiple countries, including but not limited to Vietnam, Europe and Singapore. Whenever we transfer personal information to other countries, we make sure that the transfer is done in accordance with this Privacy Policy and as authorized by applicable data protection laws.

6. How We Secure

At VinFast, security is a priority. We design our systems with your security and privacy in mind.

• We employ technical and security measures designed to prevent unauthorized access and use of your personal information. Despite our efforts, no data security measures can guarantee security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

• Your payment card information, which is issued by the relevant financial institution, is protected by us in accordance with international standards on the principle that no important data of the card (card numbers, full names, CVV number) is recorded in our system. Your payment transaction is conducted via third-party systems.

7. Internet Advertising and Third Parties

VinFast Products may include third-party advertising and links to other websites and applications. Third party advertising partners may collect information about you when you interact with their content, advertising, or services. Any access to and use of third party links or websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third party operators. We are not responsible for the information practices of third parties. To opt out of interest based advertising, please see Collection and Use of Cookies above.

Third-Party Analytics. VinFast Products may use services operated by third parties, such as Google Analytics, which uses cookies and similar technologies to understand use of VinFast Products and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources over time.

Social Plugins. We may use social plugins on our site, such as: Facebook, YouTube, Instagram and LinkedIn. When you view a site that contains a plugin, your browser will create a direct link to the third parties’ servers. If you are logged into your social media account, the social media platform will record the visit to your social media account. Please visit the social media platform’s privacy policy for more information.

8. Access and Option

You can see, update, and remove certain personal information about your account and your interactions with VinFast Products. Do let us know if you cannot access or update your personal information yourself.

You have many options in relation to the collection and use of your personal information. Many of VinFast Products include settings that provide you with options as to how your information is being used. You can choose not to provide certain information, but then you might not be able to utilize certain Products of ours.

• Account Information: If you want to add, update, or delete information related to your account, please go to your account in VinFast official website or app. When you update or delete any information, we usually keep a copy of the prior version for our records for technical purpose.

• Communications: If you do no longer want to receive promotional communications from us, and would like to withdraw your prior consent (if any) and/or object to any further use of your personal information for marketing purposes, please kindly send the opt-out message following the protocol as instructed (or use other methods specified in the relevant contracts with you). If you do no longer want to receive in-app notifications from us, please adjust your notification settings in the app or your device.

• Browser and Devices: The Help feature on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

9. Minor’s Personal Information

If you’re under the age defined by your local applicable laws and in any case under the age of 16, you may enter into contracts and accept this Privacy Policy only with the approval of your parent or guardian.

10. How Long We Store Personal Information

We retain your personal information to provide you with VinFast Products, for as long as it is needed to meet the relevant purposes described herein, as may be required by law (including for tax and accounting purposes), or as otherwise informed to you. How long we keep certain personal information will be different based on the purpose for its use, and we will adhere to the law when deleting your personal information.

We undertake to anonymize or delete your personal information as soon as the purpose and/or the duration of their established retention expire, except where further storage is necessary in the individual case to comply with our legal obligations (such as specific data retention obligations) or to establish, exercise or defend our legal claims.

The maximum retention periods set out in the table below apply unless you request for your personal information to be erased before the expiry of these periods, in accordance with your rights under applicable laws.

 

Category	Retention period
Cookies and other tracers	Please see our cookies policy for applicable retention periods
Information relating to financial transactions carried out by credit card	This information is processed by our payment service providers, only for the duration of the payment transaction
Information about VinFast Products performed, ordered and/or purchased	For the duration of our commercial relationship
Personal information processed as part of solicitations and promotional operations, sending offers and news	For the duration of our commercial relationship, then for 3 years after the end of this relationship or of the last contact you initiated. 3 years in other cases, from the last contact you initiated.
Creation of a customer account, its configuration and management of your profile	Your personal data will be kept until you delete your account
Personal information relating to the management of requests for the exercise of rights and questions on personal information	Your data will be kept for one or 6 years depending on the right exercised.
Information about managing customer service interactions and responses to any customer surveys	3 years, from the last contact you initiated.
Geolocation data	Such data is not retained beyond the period of your use of the feature
Management of your complaints and questions initiated by contacting our customer service.	During the duration of our commercial relationship. At the end of the said relationship, only the data necessary for pre-litigation or litigation purposes will be archived until the acquisition of the legal statute of limitation. In the event of a litigation procedure, the data will be kept for the duration of the procedure and until the expiration of ordinary and extraordinary remedies.

11. Contacts, Notices, and Amendments

If you have any questions about privacy at VinFast or want to contact one of our data controllers, please contact us and we will try to resolve it. You may also contact us at the address below:

Email: [email protected]

Address: 18, boulevard Malesherbes

75008 PARIS, France

Our business changes constantly, and our Privacy Policy may also change. You should check our website frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all personal information we have about you and your account. We will not change our Privacy Policy to make them less protective of personal information collected in the past without letting the relevant customers know and giving them a choice.

12. Additional Information for the EU

The following additional information about the privacy, collection, and use of personal information is provided for prospective and current customers of VinFast Products in the European Economic Area.

• Controller of Personal Information. VinFast France S.A.S is the controller of the personal information collected or processed under this Privacy Policy.

• Your Rights. Subject to applicable law, you have the right to:

• ask whether we hold personal information about you and request copies of such personal information and information about how it is processed;

• request that inaccurate personal information be corrected and to have incomplete personal information competed;

• request deletion of personal information if one of the legal grounds for deletion are met, such in scenarios where the personal information is no longer necessary for the purposes underlying the processing or processed in non-compliance with applicable legal requirements;

• request us to restrict the processing of personal information where the legal requirements are met;

• request portability of personal information that you have provided to us (which does not include information derived from the collected information), where the processing of such personal information is based on consent or a contract with you and is carried out by automated means;

• provide us with directives relative to the fate of your personal information after your death ; and

• not to be subject to a decision based solely on automated processing which produces legal effects concerning you or significantly affects you in a similar way, if the legal requirements are not met. An automated decision making process is not carried out by VinFast.

• lodge a complaint with the supervisory authority of the European Union Member State in which you usually reside if you believe that we violate your privacy rights.

You also have the right to object, in accordance with applicable data protection law, to the processing of personal data which is necessary for the purpose of VinFast’s legitimate interests, on grounds relating to your particular situation. If your personal data is processed by VinFast for direct marketing purposes, you have the right to object to this processing at any time, without any special reason.

When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.

You can exercise your rights by contacting us at the address under Section 11 above. Where applicable, we will inform you of the reasons why the rights you exercise cannot be satisfied in whole or in part.

• Transfers outside of the EU. We may transfer or process your personal information collected and stored within the EU (or otherwise subject to European data protection law) in a country outside the EU and the European Economic Area. While the laws of such country may not provide for the same level of data protection as considered adequate within the EU, we do so in accordance with the terms of this Privacy Policy and take appropriate safeguards to ensure your personal information is protected in accordance with applicable data protection law. This may include the transfer of data pursuant to data transfer agreements that incorporate the Standard Contractual Clauses approved by the EU Commission or other transfer mechanism, and the implementation of supplementary safeguards. To learn more about the recipients of your personal information, and the safeguards implemented by us, including how to receive a copy of them, please contact us at the contact details set out above (section 11).

13. Examples of Information

Information You Give Us

We mainly obtain information about you when you:

• Search for, subscribe to, use, or purchase VinFast Products;

• Create and use your account;

• Interact with VinFast Products;

• Register for or attend a VinFast event;

• Buy or use products or services from third-party providers through VinFast’s websites or apps (or other similar platforms provided by us);

• Offer your products, or services on or through VinFast Products or VinFast’s websites or apps (or other similar platform provided by us);

• Contact us through official channels such as our customer support center, call center, or email;

• Complete a questionnaire or other information request form;

• Post on VinFast’s websites or apps or similar.

Depending on your use of VinFast Products, we may obtain from you such information as:

• Your name, email and physical address, phone number, and other contact information;

• Payment information, including credit card and bank account information;

• Information about your location, miles travelled, average speed, average charge frequency, etc..;

• Your organization and your contacts’ information, such as your organization’s colleagues or people;

• Usernames, aliases, roles, and other authentication and security credential information;

• Feedback, questions, correspondences with us;

• Your image, voice, and other identifiers that are personal to you when you attend a VinFast event or use VinFast Products;

• Information regarding identity, including government-issued identification information, nationality;

• Corporate and financial information; and Value Added Tax (“VAT”), Personal Income Tax (“PIT”) numbers and other tax identifiers.

Automatic Information

We mainly automatically receive information when you:

• Interact with or use VinFast Products (including when you use your computer or other device to interact with VinFast Products);

• Download content from us;

• Open emails or click on links in emails from us; and

• Interact with us.

Examples of the information automatically collected may include:

• Information about network and connection, such as the Internet Protocol (IP) address;

• Information in relation to computer and device information (e.g., device, application, browser, browser plug-in, or operating system);

• Your device or computer’s whereabouts;

• Authentication and security;

• Content interaction information (e.g., downloads, and playback details);

• VinFast Products metrics (e.g., products usage, technical errors, reports, settings, backup information, application programming interface (“API”) calls, and other logs);

• The content viewed or searched by you, page response times, and page interaction (such as scrolling, clicks);

• Email and phone numbers to contact us; and

• Identifiers and information contained in cookies.

Information from Other Sources

Examples of information we receive from other sources include:

• Information on marketing, sales and recruitment (e.g., your name, email, physical address, phone number, and other similar information);

• Information about your interactions with VinFast Products or third parties’ products in relation to VinFast Products (e.g., subscription, purchase, support, or other);

• Search results and links, including paid listings (such as sponsored links); and

• Credit history information.