Privacy Policy

Thank you for visiting the website flowurmove.com operated by FLOW GROUP COMPANY LIMITED. We respect and are committed to protecting your privacy. Please read the Privacy Policy below to better understand the commitments we make to respect and protect the rights of our visitors.

OVERVIEW

In the capacity of a Data Controller and/or a Data Controller and Processor of Personal Data (as defined under Decree No. 13/2023/NĐ-CP issued on 17 April 2023 and effective from 01 July 2023 – referred to as “Decree 13”), this Personal Data Protection Policy (“Policy”) sets out how flowurmove.com processes the data that you provide to us or that is collected by flowurmove.com

“Data Processing” means one or more operations that impact Personal Data, such as: collection, recording, analysis, verification, storage, modification, disclosure, combination, access, retrieval, recovery, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction of Personal Data, or other related actions.

“Personal Data” means information in the form of symbols, letters, numbers, images, sounds, or similar forms in an electronic environment that is associated with a specific individual or helps identify a specific individual. Personal Data includes basic personal data and sensitive personal data.

Our website flowurmove.com may contain links to other websites/apps/platforms of third parties that are not owned or controlled by us. We are not responsible for how such websites, applications and/or platforms operate or how they process your data. Therefore, we recommend that you carefully review the personal data protection policies and related terms of such third parties.

1. PERSONAL DATA WE COLLECT

flowurmove.com collects various types of information related to the Services, including:

1.1. Personal Data you provide to us

flowurmove.com collects data about how you use our services and products, such as the type of products/services you view or are interested in, or how frequently you use our services. We also collect Personal Data you provide when you subscribe to marketing newsletters, complete a survey, or register an account to purchase our products/services. In doing so, we may request Personal Data such as your name, gender, date of birth, address, email address, phone number, or your credit card details. Please note that credit card information is sensitive personal data under Decree 13.

1.2. Personal Data flowurmove.com collects automatically

Flow Ur Move also receives and stores certain types of Personal Data whenever you interact with us online. For example, we use cookies and other technologies to collect Personal Data when your web browser accesses our websites or advertisements and other content provided by or on behalf of us on other websites. Your Personal Data may also be collected when you search, make purchases, post content, participate in events, respond to survey questionnaires, or communicate with our customer service team. Examples of the types of Personal Data we collect include: IP address, device identifiers, location data, information about your computer and connection such as browser type and version, time zone settings, browser plug-in types and versions, operating system, and purchase history—which we may, at times, aggregate with similar information from other consumers. Please note that location data is sensitive personal data under Decree 13.

The types of Personal Data we collect may include, but are not limited to, the following:

1.2.1. Contact information

For example: billing address, shipping address, email address, phone number, workplace address, permanent address, temporary address, etc.

1.2.2. Membership information

For example: membership card number, member personal information, reward points, membership joining/registration date and month, etc.

1.2.3. Financial information

For example: bank account/debit card/credit card number, account holder name, payment card type or account used, etc. Please note that such information is sensitive personal data under Decree 13.

1.2.4. Transaction information

For example: details of payments made by you (payment time, amount paid, refund details, refunded amount), purchase location, order number, service appointment date, warranty details, transaction status and/or any information arising from the use of products/services provided by us, etc.

1.2.5. Information from computers/mobile devices

For example, information about the computer system or other technology devices you use to access any of our websites, applications or platforms, such as the IP address used to connect your computer or device to the Internet, operating system, and web browser type and version. If you access our website using a mobile device such as a smartphone, the information collected, where permitted, may also include your device’s unique ID, advertising ID, and similar mobile device data.

1.2.6. Behavioral information

• Information about your purchasing behavior: We collect information about the products/services you have purchased from us. This helps us understand your preferences and provide more suitable product/service recommendations.
• Information about your online search behavior: We collect information about the keywords you searched on search engines, as well as the websites you visited. This helps us understand your interests and provide more relevant advertisements.
• Information about how you interact with Flow Ur Move products/services: We collect information about how you use them, such as the pages you visited, the products/services you viewed, and the actions you took. This helps us improve our products/services.

1.2.7. Profile information

For example: your username and password, profile details and purchase history of our products/services (including prices, purchase time, and quantity).

1.2.8. Marketing and communications information

For example: feedback regarding your level of interest when receiving surveys about promotions, media events from us, etc.

2. PROVIDING THIRD-PARTY PERSONAL DATA BY YOU

When you provide Flow Ur Move with Personal Data of other individual(s) besides yourself, you represent and warrant to us and hereby confirm that:

• Before disclosing such Personal Data to us, you have obtained valid consent from the individuals whose Personal Data is being disclosed to us for Data Processing under this Policy; and
• Any Personal Data of such individuals that you disclose is accurate and complete; and
• You validly represent such individuals and have valid authorization from them to provide their Personal Data to us and for us to collect, use, disclose and process such Personal Data for the Purposes set out in this Policy; and
• This Policy has been communicated to such individuals so that they are aware of and agree to its full contents.
• If you do not meet any of the above representations and warranties, please do not provide such individual’s Personal Data to us.

3. PURPOSES OF DATA PROCESSING

To the extent permitted by your consent and/or as required or permitted by law, Flow Ur Move may use your Personal Data for one or more of the following purposes (“Purposes”):

3.1. Providing products and services

Flow Ur Move may process your data for the purpose of operating and providing products/services to you, which may include but is not limited to: supporting and carrying out other activities related to the products/services you request; performing services and financial transactions related to payments, including transaction checks, verification and cancellation; processing orders, delivery, collection of payments, refunds and returns; providing updates regarding product delivery; verifying warranty periods; and providing after-sales services, including maintenance, servicing, transportation, etc.

3.2. Cooperation with third parties

• Flow Ur Move may provide your name, phone number and address to third parties for delivery purposes (e.g., courier services or logistics providers).
• Flow Ur Move may provide your name, phone number and email to our online payment partners (online payment gateways registered with the State of Vietnam). Please provide only accurate information to us, our partners, or the website, and notify us of any changes.

3.3. Marketing and communications

• With your consent, we may process your data to send you preferential offers, product/service updates, new product launches, sales programs, promotions, advertisements, announcements, news, and any marketing and communication activities related to our products/services. Details of such programs, including content, methods, formats, and frequency of introducing products/goods/services, will be specifically notified in each program.
• We may market and communicate with you through various channels, as appropriate, including on our Flow Ur Move website and/or via phone calls and email.

3.4. Registration and authentication

We may process your data for the purpose of registering, verifying or authenticating your identity when we provide products/services to you and/or for other purposes as required by law and this Policy.

3.5. Relationship management

We may process your data to contact and communicate with you, manage customer records, and handle information inquiries, requests, feedback, and complaints related to our products/services as requested by you.

3.6. Data analytics

We may process your data to recommend products you may be interested in, identify your preferences and personalize your experience; learn more about you and the products you receive as well as other products you may want; measure your engagement; and perform data analytics, profiling, market research, surveys, behavioral assessments, statistics and segmentation, consumption trends and patterns, etc.

3.7. Improving products/services

We may process your data to troubleshoot and diagnose issues, defects or shortcomings of products and to provide customer care and support services; evaluate, improve and develop products based on your satisfaction and consumption behavior; and measure the effectiveness of marketing/communication campaigns and business models.

3.8. To support online functions (website flowurmove.com ), mobile applications and social media platforms.

We may process your data for the purposes of managing, operating, monitoring, supervising and administering websites and online platforms, ensuring the website functions properly, efficiently and securely; and facilitating your experience on our flowurmove.com websites.

3.9. Information technology management

Flow Ur Move may process your data for the purpose of operating, improving and developing information technology systems, including ensuring information security and data protection, ensuring system availability, integrity and confidentiality, and ensuring system performance meets user needs.

3.10. Protecting common interests

Flow Ur Move may process your data to protect data confidentiality, integrity and security and our business operations; to exercise our rights or protect our legitimate interests when necessary. For example, to resolve complaints or disputes; detect, prevent and address unlawful acts; and ensure compliance with our terms and conditions under contracts and/or any documents with any third party.

3.11. Risk management and fraud detection

Flow Ur Move may process your data to verify your identity and conduct compliance checks of employees and related parties in accordance with our internal regulations and/or applicable laws.

3.12. Compliance with laws and regulations

Flow Ur Move may process your data to comply with legal regulations and requests from competent state authorities in Vietnam as well as foreign authorities—where we lawfully conduct business.

4. SHARING OF PERSONAL DATA

We may disclose or transfer your Personal Data to the following third parties in accordance with the Purposes in this Policy. The third parties mentioned below may be located within Vietnam or in territories outside Vietnam.

4.1. Service providers

We may share your Personal Data with partners and service providers, including but not limited to: internet, software, website and information technology service providers; payment service providers; media and event organizers; telecommunications service providers; logistics and delivery service providers; and other goods/service providers, etc.

4.2. Networks (Websites), social media platforms

We may optionally provide you with login features on the flowurmove.com website without requiring you to enter information into a form.

4.3. Third parties at the request of competent state authorities and/or as required by law

We are committed to protecting your Personal Data and will only disclose or share it when required by competent state authorities and/or as provided by law. In such cases, we will cooperate with competent state authorities or other third parties to comply with the law, protect our rights and yours, and prevent fraud, security, or information safety issues.

5. CROSS-BORDER TRANSFER OF DATA

Your Personal Data may be transferred by us from Vietnam (“Home Country”) to another location, city, or country outside the territory of Vietnam (“Alternative Country”). When transferring your Personal Data from the Home Country to the Alternative Country, we will comply with applicable legal obligations and regulations relating to your Personal Data, including having a lawful basis for the transfer and applying appropriate safeguards to ensure an adequate level of protection for Personal Data.

The lawful basis for cross-border transfer of Personal Data as provided in this section will be your consent to this Policy and the safeguards in accordance with applicable law.

6. DATA RETENTION AND PROCESSING PERIOD

• We only store and process your Personal Data for as long as we need such information to serve the Purposes in this Policy for you or to comply with our legal obligations. Your Personal Data begins to be processed from the time we gain access to your Personal Data.
• We will stop storing your Personal Data by securely deleting such Personal Data in accordance with the law and this Policy when (i) there is a reasonable basis to believe that such storage no longer serves the purposes for which the Personal Data was collected and is no longer necessary for any legal or business purposes and/or (ii) the retention period ends as required by law and/or (iii) there is a request from you to delete Personal Data, object to or restrict Data Processing, or withdraw consent for Data Processing.
• Notwithstanding the above, we may retain certain Personal Data to exercise our rights or to comply with this Policy or applicable laws.

7. RIGHTS AND OBLIGATIONS OF CUSTOMERS

7.1. Right to be informed

You have the right to be clearly, transparently and fully informed about how we process your data, including what rights and obligations you have with respect to Personal Data being processed by us, unless otherwise provided by law.

7.2. Right to consent and withdraw consent

• You have the right to consent to our processing of your data under this Policy (specifically, we rely on your consent as a lawful basis for Data Processing).
• You have the right to withdraw your consent, unless otherwise provided by law, at any time by notifying us (however, withdrawal of consent does not mean that Data Processing of your Personal Data that took place before the withdrawal was unlawful).

7.3. Right to access and rectification

• You have the right to access, edit, or request us to edit any Personal Data about you that we are processing, unless otherwise provided by law.
• We are not responsible for issues arising where Personal Data provided by you is (i) falsified/inaccurate (in whole or in part) or (ii) misleading or (iii) incomplete/not comprehensive/not relevant or (iv) not updated to us regarding any changes to your Personal Data and/or other cases as provided by law.

7.4. Right to erasure

You have the right to request that we delete part or all of your Personal Data, unless otherwise provided by law. Please note that this is not an absolute right in all cases, as we may have legal grounds to retain your personal information for compliance purposes and/or requests from competent state authorities.

7.5. Right to restriction of Data Processing

You have the right to request restriction of our Data Processing of your Personal Data, unless otherwise provided by law. This right means the scope of Data Processing for your Personal Data will be limited, so we may store the information but may not further use or process it.

7.6. Right to data provision

You may request that we provide you with a copy of your Personal Data that we hold.

7.7. Right to object to Data Processing

You have the right to object to the processing of your data to prevent or restrict disclosure of Personal Data or its use for advertising and marketing purposes, unless otherwise provided by law.

7.8. Right to complaint

Customers have the right to submit a complaint about personal information being disclosed to third parties to the Website Administration of Flow Ur Move via the contact information in Section 12. Upon receiving such feedback, Flow Ur Move will verify the information and is responsible for responding with the reasons and guidance for customers to review and secure their information.

7.9. Right to claim compensation

You have the right to claim compensation for damages in accordance with applicable law when there is a basis to believe that we violate personal data protection regulations, unless otherwise agreed by the parties or provided by law.

7.10. Right to self-protection

• You have the right to self-protection in accordance with the Civil Code and applicable laws, or request competent authorities/organizations to apply civil rights protection measures as provided by the Civil Code.
• We strive to handle your requests promptly, fairly and transparently. However, we reserve the right to refuse requests that are unfounded, repetitive, or that violate our legitimate rights and interests or those of any third party, or that are outside our authority/scope of data processing. We will notify you of the reasons for refusal and how to remedy, if possible.
• You may exercise these rights by sending an email to us under the “Contact Us” section and attaching relevant documents (when requested by us and/or permitted by law). If a request is made by someone other than you but such person cannot provide evidence that the request is lawfully made on your behalf with your valid consent, the request will be rejected.
• For your privacy and information security, we may request that you verify your identity before we fulfill your request to exercise the rights stated in Section 7 of this Policy.

7.11. Customer obligations

• Provide complete and accurate Personal Data when you consent to our Data Processing;
• Respect and protect other people’s Personal Data;
• Comply with other legal requirements and obligations applicable to data subjects under the law.

7.12. Notes on potential consequences and unintended damages

• If you exercise one or more of your rights, we may (i) be unable to take necessary actions to achieve the processing purposes described in this Policy for you; and/or (ii) be unable to perform or enter into contracts that we have entered into or are attempting to enter into with you; and/or (iii) be unable to provide you with our products/services.
• Your exercise of rights and these unintended consequences will be deemed termination from your side of any relationship you have with us, and/or a breach of obligations and commitments under contract. For clarity, we expressly reserve our legal rights and remedies in such cases and will not be liable to you for any losses, damages, claims or disputes arising from your exercise of rights as stated above.

8. DATA PROTECTION

We have implemented and continue to implement various technical and organizational measures to protect and secure your Personal Data, such as:

• Members’ personal information on Flow Ur Move is strictly protected in accordance with Flow Ur Move’s personal information protection policy. The collection and use of each member’s information is only carried out with your consent except where otherwise required by law;
• Implementing information security policies, rules, and technical measures to protect Personal Data and comply with legal requirements;
• Conducting cybersecurity checks for systems and means/devices used for processing Personal Data before processing; and irreversibly deleting or destroying devices containing Personal Data;
• Training and requiring employees who access customers’ personal data to comply with our data privacy and security standards;
• Requiring our service providers or other third parties with whom we cooperate and to whom we disclose customers’ personal data to implement similar standards and measures regarding security, privacy and data protection when they process your data.
• In the event that the hosting server is attacked by hackers resulting in loss of customers’ personal data, Flow Ur Move will be responsible for promptly notifying competent authorities for investigation and handling, and informing customers accordingly.

9. CHILDREN’S PRIVACY

• Children are individuals under 16 years old under current Vietnamese law, and this age definition may change depending on legal regulations from time to time.
• We have applied, are applying, and will always apply additional and appropriate safeguards to help ensure the safety of children’s Personal Data, based on the principle of protecting children’s rights and in the best interests of children.
• Before processing children’s data, we require the child’s consent if the child is 07 years old or older, and the consent of the parent(s) or lawful guardian as required by law.
• We will take necessary measures, as required by law, to verify age before processing children’s data. You understand that if you provide us with Personal Data of a child, you must prove that you are the parent or lawful guardian of the child, or that you have obtained valid consent and authorization from the parent(s)/lawful guardian before providing such data.
• We will cease Data Processing and may delete or destroy children’s Personal Data where necessary to protect children’s lawful rights and interests in accordance with applicable law and our business criteria, for example: (i) when the child or the child’s parent(s)/guardian withdraws consent for processing; or (ii) at the request of competent authorities.
• If a child’s Personal Data is disclosed to us by you in breach of the above requirements and we cannot know and/or verify at the time you provide it, you hereby agree to the processing of that child’s data and accept to be bound by this Policy and take responsibility for any issues arising in relation to such child’s Personal Data. We will not be responsible for any unauthorized use of our products/services provided by you and related parties in violation of this Policy.

10. COOKIES

• A cookie is a text file placed on your hard drive by a web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer and can only be read by a web server in the domain that issued the cookie to you.
• We use cookies to personalize and optimize your online experience and help you use your time online more effectively when visiting the Flow Ur Move website without having to re-register existing information.
• You may accept or decline cookies. Most browsers automatically accept cookies, but you may change your settings to decline all cookies if you prefer. However, if you choose to decline cookies, this may hinder and negatively affect certain services and features on the website/app that depend on cookies.

11. UPDATES TO THIS PERSONAL DATA PROTECTION POLICY

• We may review, revise, or automatically update this Policy on our flowurmove.com websites at our sole discretion from time to time, to ensure updates are consistent with our business operations and compliant with changes in applicable laws. If such changes are material, we will provide a more prominent notice (via a general announcement published on our Flow Ur Move website at our sole discretion or sent to the email address you provided).
• You agree that you are responsible for reviewing this Policy regularly to stay informed of the latest information on how we process your data. Therefore, your continued use of the Flow Ur Move website at our sole discretion or use of the products/services we provide after any amendments to this Policy constitutes your acceptance of this Policy and all amendments (if any), and the processing of your data under this Policy and all amendments (if any).

12. CONTACT US

If you have any questions, complaints, or feedback regarding how we process your data, or if you wish to exercise any rights mentioned in this Policy, please contact us using the information below:

Personal Data Protection Department:

• Mailing address: 268 Duong Dinh Nghe, An Hai, Da Nang
• Email address: cskh@flowurmove.com.vn 

CONSENT

• Please read this policy carefully and ensure that you have read and understood all contents of this Policy, and that you agree and authorize us to process your data in accordance with this Policy.
• If you do not agree with any part of this Policy, please do not continue to access the website or provide/send Personal Data to us. You may submit feedback, complaints, or questions via the “CONTACT US” section for assistance.