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Techcombank Data Privacy Statement

This Enterprise Data Privacy Statement (the “Statement”) is provided by Vietnam Technological and Commercial Joint-Stock Bank and its subsidiaries and affiliates (together as “Techcombank”, “we” or “us”) and describes Techcombank’s practices regarding the collection, storage, use, disclosure, and other Processing of Techcombank customer’s personal information.

 

Scope of this Statement

This Statement governs the manner in which Techcombank collects and processes customer Personal Information regarding individuals who use or otherwise interact with Techcombank’s products, websites or services (“you”). We encourage you to read this Statement carefully and to regularly check this page to review any changes we might make in accordance with the terms of this Statement.

Please note that this Statement does not apply to the processing by Techcombank of the Personal Information of Techcombank’s employees, contractors, temporary workers or other staff in connection with the roles they perform for Techcombank.

If you have additional questions you may contact our branch(es)/transaction office(s) or call us at 1800588822/ 84-24 3944 6699 for more information.

 

Types of Personal Information We Collect

The types of Personal Information that may be collected by, or on behalf of, Techcombank under this Statement may vary by jurisdiction and applicable laws. The categories listed below are indicative but not exhaustive, and may change depending on your interactions with Techcombank. These categories include:

  • Personal details: name; gender; photograph; date of birth; profession; business or employer; sector
  • Contact details: email address; postal address; telephone number; fax number; customer ID
  • Data relating to Sites or Apps: technical data (as outlined above, including device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site, App usage statistics, App settings, dates and times of connecting to the App, location data, and other technical communications information); username; password; security login details; usage data etc.
  • Commercial details/Customer’s transaction information: financial details and payment information (including bank details or credit card details provided in connection with a purchase); purchase history (including products, dates, locations and branches relating to any purchase); purchase interests; service requests; credit-related information and other information as regulated by applicable laws, jurisdiction;
  • Marketing data: advertising interests; cookie data; clickstream data; browsing history; responses to direct marketing; and opt-outs from direct marketing.

 

How Personal Information is Collected and Collection Methods

Techcombank may collect Personal Information in the following circumstances:

 

Directly From You

  • From our Sites:  Techcombank may collect or obtain personal information when you visit any Techcombank’s website (each a “Site”) or use any features or resources available on or through a Site. When you visit a Site, we collect information about your device and browser (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), all or some of which may constitute Personal Data.
  • From Mobile Apps: Techcombank may collect or obtain personal information when you download or use a Techcombank’s mobile app (each an “App”). Techcombank Apps may record certain information (including App usage statistics, device type, operating system, App settings, IP address, language settings, dates and times of connecting to the App, location data, and other technical communications information) all or some of which may constitute personal information. An App used by Techcombank may have its own Privacy Policy, which you are encouraged to review before using the relevant App
  • From Services: Techcombank may collect or obtain personal information when you register to use any service provided via a Site or an App, or log into a Site or an App.
  • From communications with you: Techcombank may collect or obtain personal information when you contact Techcombank (whether in person, by mail, by phone, online, via electronic communication or by any other means) including our customer surveys.
  • From automated interactions or data collection technologies. Techcombank may collect information including IP address, referring URL, operating system, web browser and any other information automatically logged from the connection.
    • Cookies, flash cookies, pixel tags, web beacons, or other tracking technologies.
    • Third-party cookies, plug-ins, or social media connectors.
    • Any technology capable of tracking individual activity across devices or websites.
    • Location information or other meta-data provided by a device.
  • Other Means: Techcombank may collect or obtain Personal Data when you interact with Techcombank via any other means.
  • Social Media. Social Media Sites, third party data suppliers.

 

Techcombank may receive Personal Information about you from other third parties

For example:

  • If you choose to interact with third party content or advertising on a Site or in an App, Techcombank may receive personal information about you from the relevant third party, in accordance with that third party’s applicable and legitimate privacy policy.
  • If you choose to make an electronic payment directly to Techcombank, or through a Site or an App, Techcombank may receive personal information about you from third parties such as payment services providers, for the purposes of that payment.
  • In complying with its obligations under applicable laws, Techcombank may receive personal information about you from law enforcement agencies and public authorities.
  • Techcombank may receive personal information about you from public sources (such as telephone directories, advertisement/flyers, public information on websites, etc.).

Whenever you provide any such personal information, you must ensure that any affected third parties have consented to: (i) the disclosure of their personal information to Techcombank; and (ii) Techcombank’s further Processing of the personal information in accordance with this Statement. If you cannot obtain such consent, please refrain from communicating the personal information of third parties to Techcombank.

 

How Personal Information is Used and Shared

Techcombank may process your personal information for the following purposes:

  • To provide requested goods or services;
  • To send you information relevant to your past deals and interests, subject to compliance with Applicable Laws regarding direct marketing;
  • Online behavioral advertising or interest-based advertising;
  • To display the content of a Site, an App or a Device, and any customizations you may select;
  • To monitor, adapt, update, secure and improve our products, services, Sites, Apps, Devices or our customer service;
  • To verify your identity and ensure the security of your personal information;
  • To respond to your service requests and support needs;
  • To administer content, promotions, surveys or other features of a Site, an App, or a Device;
  • To send you communications regarding administration of your accounts and the features of a Site, an App, or a Device;
  • To notify you about changes to a Site, an App, or a Device;
  • To perform internal data analyses and other Processing (including trend analysis and financial analysis);
  • To give effect to your legal rights and your rights under this Statement;
  • To protect against fraud, identity theft, and other unlawful activity;
  • To establish or exercise Techcombank’s legal rights or defend legal claims;
  • To establish or exercise legal rights, or defend legal claims;
  • To comply with Applicable Laws, relevant industry standards and our other applicable policies;
  • Any other purposes unique to our business operations; and
  • In any other way that we notify to you, either at the time of collection of your personal information or before the commencement of the relevant Processing or as otherwise required or permitted by applicable laws

 

Protection of your Personal Information

Techcombank is committed to processing your personal information securely.

We adopt appropriate data processing practices, and appropriate technical and organizational security measures, to protect against unauthorized access, read, use, alteration, disclosure, destruction or other processing of personal information. The Internet is not, in itself, a secure environment and we cannot provide an absolute assurance that your personal information transferred using the Internet will be secure at all times. Transmission of personal information over the Internet is at your own risk and you should only use secure systems to access Sites, Apps or Devices. You are responsible for keeping your access credentials for each Site, App and Device safe and confidential. You should notify Techcombank promptly if you become aware of any misuse of your access credentials, and immediately change your passwords.

 

Disclosure of your Personal Information

We will not sell, trade, or rent your personal information to others without obtaining your consent in accordance with Applicable Law. We may share or disclose your personal information to third parties in the following circumstances:

  • We may share your personal information with employees and agents of Techcombank, for the purposes set out in this Statement.
  • We may share your personal information with recipients within Techcombank, for the purposes of operating our business, operating Sites, Apps or Devices, providing you with products or services you have selected, or otherwise for the purposes set out in this Statement.
  • We may share your personal information with recipients outside Techcombank, including partners, for the purposes of operating our business, operating Sites, Apps or Devices, providing you with products or services you have selected, or otherwise for the purposes set out in this Statement.
  • We may use third party service providers to help us operate our business, operate Sites, Apps or Devices, provide you with products or services you have selected, or to administer activities on our behalf, such as sending out newsletters or surveys.
  • We may share your personal information with such third parties for the purposes set out in this Statement. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes.
  • We may share aggregate demographic information with our business partners, trusted affiliates and advertisers for the purposes outlined in this Statement.

We may also disclose your personal information if required by courts, government agencies and/or allowed by applicable laws or regulations.

While we make all reasonable efforts to ensure that such information is anonymized/masked, it is possible that your Personal Data may be disclosed in some force majeure circumstances.

Subject to providing prior notice and/or obtaining your consent as required under Applicable Law, we may share your personal information with our third party marketing partners, for direct marketing purposes. You may withdraw your consent at any time, or object at any time to the Processing of your Personal Information for direct marketing purposes in accordance with Applicable Law and we will apply your marketing preferences going forward.

If you make a payment via a Site or an App, or directly to Techcombank, your personal information may need to be provided to third parties (e.g., payment services providers) for the purposes of facilitating those payments.

In the event of a proposed or completed sale, merger or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, liquidation or other restructuring or change in control), we may disclose your personal information to the prospective seller or buyer, or their representatives, provided that we have first taken reasonable, lawful steps to ensure the security and confidentiality of your personal information.

 

Third party services

You may encounter advertising or other content on any Site, App or Device that may link to websites or services of Techcombank’s partners, advertisers, sponsors, or other third parties.

We do not control the content or links that appear on these third party websites or services, and we are not responsible for the practices employed by third party websites or services linked to or from any Site, App or Device.

These websites and services may be subject to their own privacy policies and terms of use.

 

Direct Marketing

As set out in this Statement and in accordance with requirements under Applicable Law, we, our direct marketing partners, or our service providers, may contact you via email, text message, or other electronic means, from time to time, to provide you with information relating to products or services that may be of interest to you.

If you wish to unsubscribe from these communications, we include detailed unsubscribe instructions in each such communication. Alternatively, you may use the unsubscribe features provided through our Sites and Apps. Please note that, in the event that you unsubscribe from receiving communications relating to marketing or advertising, we may nevertheless continue to contact you for the purposes of carrying out your instructions, enabling you to make any purchases you request, sending you transactional messages, administration of your account, or as required or permitted by Applicable Laws.

 

Cookies

When you use or visit our websites, we may place one or more cookies on your device. A “cookie” is a small file that is placed on your device when you visit a website. It records information about your device, your browser and, in some cases, your preferences and browsing habits. We may use this information to recognize you when you return to our websites, to provide personalized services on our websites, to compile analytics in order to better understand website activity, and to improve our websites. You can use your browser settings to remove or block cookies on your device. However, if you decide not to accept, or to block, cookies from our websites, you may not be able to take advantage of all of the features of our websites.

We may process your personal information through cookie technology, in accordance with the provisions of this Statement. We may also use remarketing tags to serve advertisements to people who we know have previously visited our websites

To the extent that third parties have embedded content on our websites (e.g., social media features) those third parties may collect your personal information (e.g., cookie data) if you choose to engage with such third party content, or otherwise use third party services.

 

Data retention

We will only retain your personal information for as long as we require it in connection with the purposes set out in this Privacy Statement. We may also be required to retain your personal information for additional periods of time, for example, where required to do so by Applicable Laws.

 

Acceptance of this Statement

By using any Site, App or Device, you are deemed to have accepted this Statement. If you do not accept the terms set out in this Statement, you must not use any Sites, Apps or Devices.

 

Amendments to this Statement

Techcombank may amend, revise or update this Statement at any time.

We may not provide you with any specific notice but we will post any changes to this Privacy Statement as a notification on the Site. You are encouraged to frequently check this Statement for any changes, and to stay informed about how we are helping to protect your Personal Information.

 Your continued use of any Site, App or Device is deemed to be acceptance of any amendments to this Statement.

This Statement was first made available on: 17/09/2021.

 

Glossary in this Statement

Applicable Laws means all binding laws, statutes or regulations applicable to Techcombank.

Personal Information means information that is protectable under data privacy or data protection provisions under Applicable Laws.

Process or Processing means any operation or set of operations which is performed upon personal information, whether or not by automatic means, including but not limited to: collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction

Third parties mean an entity that is not a TCB’s Legal Entity that contracts to provide products or services. These entities include but are not limited to the followings:

  • Individuals or independent companies, and
  • Entities in which TCB does not directly or indirectly control a majority ownership
  • The use of the term “third party” in this document includes third parties who are not designated as suppliers.