PERSONAL DATA PROTECTION POLICY

Morinaga Milk Industry Co., Ltd. and Morinaga Milk Vietnam Co., Ltd. (collectively, “we”, “our”, “us” or “Morinaga”), take our responsibilities under the Law on Electronic Transactions No. 51/2005/QH11 (Nov. 29, 2005) and other Vietnamese laws relating to protecting personal data in Vietnam (collectively, the “Laws”) seriously, and are committed to protecting your personal data.

This Personal Data Protection Policy (“Policy”) is designed to assist you in understanding how we collect, use, disclose, store and/or process the personal data you have provided to us in Vietnam. Please read this Policy carefully to understand our practices regarding your personal data and how we handle it. By visiting or using this website (https;//www.morinagamilk.com.vn/) (“Website”), you agree to the terms of this Policy.

We may update this Policy from time to time. Any changes we make to this Policy will be posted on this page, and your continued access of this Website or use of any of the services, features, data, software and content accessible through this Website, shall constitute your acknowledgment and acceptance of the changes we make to this Policy.

1. Introduction
1. This Policy applies to personal data that is in our possession or under our control, and personal data which is collected, used, disclosed and/or processed by us in Vietnam.
2. Unless you withdraw your consent in accordance with the procedure set forth in this Policy, we may continue to share the personal data that we collect from you with our affiliates and subsidiaries. Such personal data may also, subject to the Laws, be transferred to and used by us outside of Vietnam. When personal data is collected by or transferred to us, it will be treated according to the personal data protection practices set forth in this Policy.
2. Collection, Use and Disclosure of Personal Data
1. Subject to the Laws, we will obtain consent before collecting, using and disclosing your personal data and notify you of such purposes. In doing so, we shall make a reasonable effort to ensure your personal data collected is accurate and complete.
2. We collect various types of personal data. In this Policy, “personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we (and all our affiliates, partners, subsidiaries and all relevant third parties mentioned in this Policy) have or are likely to have access.
3. We collect personal data about you that you knowingly and voluntarily provide in connection with certain activities or transactions with us, including but not limited to, when you submit employment application forms; when you register to use this Website or our services; and when you report a problem with this Website or the services, etc. The type of personal data that we collect about you depends on the nature of the activity or transaction.
4. We may also collect your personal data from, and disclose your personal data to, our business partners (including any business which we may engage to process payments or to perform delivery services), affiliates and independent third party sources for the Purposes as prescribed in Article 3 mentioned below.
5. The personal data which we may collect includes the following:
  - (a) personal information, such as your name, gender, date of birth; nationality; marital status; photograph;
  - (b) contact information, such as billing address, delivery address, email address and mobile phone or land line numbers;
  - (c) account information, such as user ID and password, usage of your account, details of products or services that you have purchased or obtained through the platform;
  - (d) payment information, such as bank account number, credit card numbers, and any other payment details;
  - (e) technical information and web-tracking data, such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, international mobile equipment identity, device identifier, how you use and view any content on this Website and other information and technology on the devices you use to access this Website;
  - (f) biometric information, such as voice files when you use our voice search function or when you contact us through our customer support hotline;
  - (g) employment-related information (e.g. curriculum vitae, job history, references);
  - (h) marketing and communications information, such as such as your preferences in receiving marketing from us, our affiliates and partners, and any third parties and your communication preferences.
6. Morinaga will not collect, use or disclose your National Registration Identification Card (NRIC) number or other national identification numbers (including Foreign Identification Number, Birth Certificate number, Passport number and Work Permit number) unless such collection, use or disclosure is required under the law (or an exception under the Laws applies); or such collection, use or disclosure is necessary to accurately establish or verify your identity to a high degree of fidelity.
7. This Website may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable data protection policies of those websites to determine how they will handle any information they collect from you.
8. When you provide your personal data to us, you are giving us permission to use and store that information consistent with this Policy, including storage in servers outside of Vietnam as prescribed in Article 7 of the Policy, subject to the requirements of the Laws on cross-border data transfers.
9. If you provide personal data of any third party to us, you represent and warrant that you have obtained the necessary consent, license and permissions from that third party to share and transfer his/her personal data to us, and for us to collect, store, use and disclose that data in accordance with this Policy. You are also required to provide legal documents to prove that you have obtained the necessary consent, license and permissions.
10. The user’s age is required to be provided. If the user is under the age of 16 at the time of providing information, a copy of one of the following documents must be provided to confirm the user’s real age: ID card/ Birth Certificate/family register. We may require you to provide additional contact information for the user’s parent or guardian as regulated for processing personal data.
3. Purposes for Collection, Use and Disclosure
1. Depending on your relationship with us, the personal data which we collect from you may be collected, used and disclosed for the following (non-exhaustive) purposes:
  - (a) to verify your identity, and to manage and administer the online account that you may have set up with us;
  - (b) to facilitate your use of the services or access to this Website;
  - (c) to process orders you submit through the Website (including any payments that you make through this Website for products, whether sold by us our any of our affiliates);
  - (d) to verify and carry out financial transactions in relation to payments you make online, and to ascertain your identity for anti-money laundering, suspicious transactions reporting and fraud detection purposes;
  - (e) to deliver the products that you have purchased through this Website, whether sold by us or a third party seller, and to verify delivery of the products. We may pass your personal data on to a third party in order to make delivery of the product to you (for example to our courier or supplier);
  - (f) to communicate with you and to process and respond to your queries, feedback, claims or disputes, whether directly or through any outsourced customer service vendors; to inform and invite you to upcoming Morinaga events;
  - (g) to update you on any of our products and services as well as the latest developments at Morinaga;
  - (h) to improve this Website; to improve the services provided and products sold;
  - (i) to manage or terminate the employment relationship, or to assess the suitability and eligibility of a prospective job candidate;
  - (j) to carry out market research on our users demographics, advertising or purchasing preferences, and other behaviour;
  - (k) to provide you with information we think you may find useful or which you have requested from us, including information about our or affiliates’ products and services, provided you have indicated that you have not objected to being contacted for these purposes;
  - (l) to comply with a court order or other legal process or other statutory and/or regulatory requirements of any governmental and/or regulatory authorities; and
  - (m) any other purpose described to you from time to time at the point of collection of your personal data.
  - (collectively, “the Purposes”)
4. Cookies
5. Sharing of Personal Data
1. We may share your personal data with third parties, related companies and our affiliates for any of the abovementioned purposes, facilitating your use of this Website or any services provided by us, completing a transaction with you, managing your account and our relationship with you, marketing and fulfilling any legal or regulatory requirements and requests as deemed necessary by us.
2. In sharing your personal data with external parties, we endeavour to ensure that the third parties and our affiliates and related companies keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as they need your personal data to achieve the abovementioned Purposes.
6. Accuracy of Personal Data
1. It is important that the personal data you provide to us is accurate and complete. You are responsible for informing us of changes to your personal data, or in the event you believe that the personal data we have about you is inaccurate, incomplete, misleading or out of date.
2. You can update your personal data anytime by contacting us in accordance with Paragraph 13.1 below.
3. We may take steps to share the updates to your personal data with third parties and our affiliates with whom we have shared your personal data if your personal data is still necessary for the above Purposes.
7. Transfers of Personal Data Outside Vietnam
1. By providing us with your personal data, you understand and agree that your personal data may be transferred to servers located at Ho Chi Minh City, Vietnam. In addition, to ensure that you are aware of the storage address and/or the processing address when transferring your personal data outside Vietnam, including transferring data to our affiliates, we will notify you to obtain your consent.
2. In situations where we transfer your personal data overseas, we shall take steps to ensure that appropriate levels of protection necessary to maintain the security and integrity of your personal data are in place. We shall ensure that the recipient organisation is able to provide the transferred personal data with a standard of protection comparable to that under the Laws.
8. Withdrawal of Consent
1. You may, at any time, communicate the withdrawal of your consent to the continued use, disclosure, storing and/or processing of your personal data for any of the Purposes as stated above by contacting us in accordance with Paragraph 13.1 below.
2. Please note that if you withdraw your consent to our use, disclosure, storing or processing of your personal data for the Purposes as stated above, we may not be able to continue to provide the services to you or perform on any contract we have with you, and we will not be liable in the event that we do not continue to provide the services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.
We will respond to your request as soon as possible to confirm your withdrawal of consent. If we cannot respond to your request within seven (07) days from your requesting date, we will notify you in writing. If we are unable to fulfil your withdrawal, we will generally inform you why we cannot do so (except otherwise specified in applicable data protection laws).
9. Access to and Correction of Personal Data
1. You may, at any time, request to access your personal data in our possession, or enquire about the ways in which your personal data may have been used, disclosed, stored or processed by us for the past year. You may also, at any time, request to correct any error or omission in your personal data records.
2. In order to facilitate the processing of your access or correction request, it may be necessary for us to request further information relating to your request. To offset costs incurred to Morinaga, we may require you to pay a little fee, not exceeding VND 3,000 for making this request.
3. If you wish to access, or correct an error or omission in, your personal data records, please contact us in accordance with Paragraph 13.1 below. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within seven (07) days from the date of your request, we will inform you in writing. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the applicable data protection laws).
10. Retention of Personal Data
1. We may retain your personal data for as long as the purpose for which the personal data was collected continues, or if the retention is necessary for our legal or business purposes, even in circumstances where you have closed your account with us. We will cease to retain personal data once we have no reason for doing so.
11. Security of Personal Data
1. We take reasonable care of your personal data. We have implemented technical, procedural and other measures to protect your personal data from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. We shall adopt technical measures to guarantee data and computer network security and personal information security and protection; and prevent illegal access, use, change or transmission of personal information and other illegal acts through the following methods:
  - (a) apply a technical infrastructure security management process which includes (but is not limited to):
  - - Formation of a firewall system:
  - - Use of accounts and passwords
  - (b) Require all employees and related parties to sign confidentiality agreements with strict sanctions to ensure no violation of personal data collected
12. Compliance with laws
1. This Policy will be updated and revised from time to time to ensure compliance with the new legal regulations of Vietnam.
2. Any content that is not specified in this Policy will be implemented under the laws of Vietnam.
13. Contact Us
1. If you have any questions on this Policy or if you have any other queries in relation to how we may manage, protect and/or process your personal data, please contact us by telephone or email to the following number or address:

Telephone number: +84-28-7108 7770

Email Address: info@morinagadairy.com.vn

This Policy is accurate as of February 2021.