BOTOL VIETNAM COMPANY LIMITED (“the Company”) and its Affiliates (hereinafter collectively referred to as (“BOTOL”) commit to respecting and making efforts to ensure the confidentiality and rights of Data Subjects regarding Personal Data. In the process of processing Personal Data of Data Subject, BOTOL will implement and comply with the provisions of the Personal Data Privacy Policy for Data Subjects (the "Privacy Policy").

 

This Privacy Policy regulates and governs BOTOL’s processing of Personal Data of Data Subjects (as defined below) in registering to participate in BOTOL's activities and events, learning/ researching about, registering to use, using or participating in the process of providing Products, Services (as defined below) of BOTOL, entering into contracts with BOTOL and/or providing Personal Data to BOTOL on any platform and/or in any form permitted. For the Personal Data of Data Subject, BOTOL is the Data Controller cum Processor.

 

This Privacy Policy is publicly available on BOTOL’s website at https://www.botol.sg/privacy-policy and BOTOL's mobile applications named BOTOL listed on Google Play and App Store (“BOTOL App”).

 

1. Definitions

 

• Personal Data: means information in the form of symbols, scripts, numbers, images, sounds or similar forms in the electronic environment attached to a specific Data Subjects or helping to identify a Data Subject. Personal Data includes Basic Personal Data and Sensitive Personal Data as regulated under the Applicable Laws on personal data protection.

 

• Data Subject: means an individual who is reflected by Personal Data, including but not limited to:

1. Individual users in cases where the users provides information to BOTOL via the Machine or BOTOL App, or through recordings and footage stored by recording devices or cameras at BOTOL’s Machines, or through registration documents, transaction materials between the users and BOTOL when using BOTOL’s Products, Services, or when the users participates in surveys, contests, and promotional programs for users on BOTOL’s digital platforms, or through the communication systems between BOTOL and the users - including past, current, and potential users (hereinafter collectively referred to as “Users”);

2. Job candidates, individual customers, services providers, partners, collaborators, and agents of BOTOL; and

3. Shareholders and other individuals related to or arising from a relationship of inquiry, registration, or use of BOTOL’s Products, Services, or any other legal relationship with BOTOL.

 

• Personal Data Controller means an organization that decides on the purposes and means of processing Personal Data.

• Personal Data Controller cum Processor means an organization that simultaneously decides on the purposes, means and directly processes Personal Data.

• Personal Data Processor means an organization that performs the processing of raw data on behalf of the Personal Data Controller, through a contract or agreement with the Personal Data Controller.

• Process/ Processing: means performing any operation or set of operations with respect to Personal Data, including collection, recording, analysis, confirmation, storage, editing, publicity, combination, access, retrieval, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction or other relevant actions.

• Affiliates mean any other entity directly or indirectly controlled by BOTOL, controlled by or under the control of BOTOL from time to time.

• Consent of Data Subject: Refers to the written consent given by Data Subjects to BOTOL, expressing their consent  to the Processing of Personal Data, and which has been validly agreed upon by Data Subject.

In the case of registering for inquiries, using Products, Services, entering into contracts, and/or providing Personal Data to BOTOL via any online platform, Data Subject’s Consent is the clear, voluntary expression of Data Subject’s agreement, authorizing BOTOL and/or a Personal Data Processor authorized by BOTOL to process Data Subject’s Personal Data. This consent is provided by clicking and checking the Cookie box stating “I agree with the Personal Data Privacy Policy of BOTOL” or similar declarations displayed on BOTOL’s Machine, BOTOL App and/ or website or any of other platforms.

• Products, Services: Includes the products, services, and benefits of BOTOL and/or products, services, and benefits from third parties with which BOTOL has partnerships.

• Machine: means Botol Equipment or BOTOL™ Reverse Vending Machines (“RVM(s)”) which are automatic machines for collecting and sorting bottles and cans.

• Competent Authorities: means the government agencies lawfully empowered to oversee, manage, or enforce regulations related to personal data protection in accordance with the Applicable Laws of Vietnam. This includes, but is not limited to, the Ministry of Public Security (MPS), particularly the Department of Cybersecurity and High-Tech Crime Prevention (A05), which is responsible for the supervision, investigation, and enforcement of personal data protection matters.

• Applicable Laws: means all laws, rules, statutes, ordinances, regulations, or enforcement orders of any Competent Authorities of Vietnam as may be amended and having enforceability relevant to the implementation of the processing and protection of personal data of the Data Subjects and the operations of the Company from time to time.

• Any terms or definitions not explained in this Privacy Policy shall have the meaning as defined inApplicable Laws.

 

1. Data that BOTOL may Process

   1. Personal Data

 

• Registration data:  If necessary, BOTOL may Process Personal Data of Data Subjects including full name, email address, phone number and password; identity card number, personal identification number, passport number; date of birth; gender; nationality, place of birth, contact address; and other Basic Personal Data (if any) under the Applicable Laws from time to time. This information is essential for account creation, security and communication purposes.

• Other Basic Personal Data that Data Subjects provide through the normal operation or use of the Machines, BOTOL App and Products, Services of BOTOL such as feedback, ratings and comments; information about how Data Subjects interact with Machines, BOTOL App, or use of Products, Services of BOTOL (such as features used, and content viewed); and

• BOTOL also Processes the data on an individual’s location determined through location services (IPS addressing), which is a Sensitive Personal Data under the Applicable Laws;

 

1. Transaction Data that are made on the Machine and BOTOL App for using Products, Services: BOTOL keeps detailed records of all transactions that Users conduct through the Machine and BOTOL App. This includes information such as transaction date and time, number of bottles and cans recycled, items or services purchased, and any rewards earned from transactions, etc. This data helps BOTOL manage Users’ transaction history and provide customer support.

 

1. Device information

 

BOTOL also collects information about the device Data Subjects use to access BOTOL App to ensure compatibility and optimize performance. This includes:

• Device model: The make and model of Data Subjects’ device (e.g. iPhone 12, Samsung Galaxy S21);

• Operating System: The operating system Data Subjects’ device is running (e.g. iOS, Android) and its version;

• Unique device identifier: Unique identifier such as IM EI, MAC address or Advertising IDs help BOTOL track app usage and device interactions; and

• Network information: Information about the network Data Subjects is using to connect to the application, such as IP address, mobile network and service provider.

 

1. Processing purposes

 

BOTOL may collect and process Personal Data for purposes related to Data Subject’s research, participation in activities, cooperation with BOTOL, and use of BOTOL’s Products, Services (“Purposes”), including but not limited to the following:

 

1. Verifying Data Subjects’ identity

 

• Verify the identity, accuracy and completeness of the information provided by Data Subjects;

• Perform tasks for activities and events organized/ conducted between BOTOL and Data Subjects;

• Perform BOTOL's rights and obligations under the contracts and agreements between BOTOL and Data Subjects;

• Monitor, urge and evaluate the performance of Data Subject’s obligations to BOTOL;

• Receive and handle requests, suggestions and complaints of Data Subjects;

• Notify, communicate, and support Data Subjects during the use of BOTOL’s Machines, BOTOL App and Products, Services;

• Communicate with Data Subjects on certain issues, including but not limited to: transaction content, providing updates on changes to BOTOL’s Machines, BOTOL App and Products, Services; reports, changes to BOTOL's internal regulations and management policies, general terms and conditions of transaction, or other relevant documents;

• Analysis of business strategy, sales strategy for BOTOL;

• Develop programs and policies related to the use of Machines, BOTOL App and Products, Services, including but not limited to marketing programs, promotions, customer care policies, warranty policies, gift programs, discounts, or other special offers, etc.; and

• Protect the legitimate rights and interests of Data Subjects and BOTOL to comply with Applicable Laws.

 

1. Providing Machine and BOTOL App features to Users

Personal Data of Users will be used to provide, personalize, maintain, and improve BOTOL’s Machines, BOTOL App and Products, Services. This includes using Personal Data to:

• Initiate, confirm, manage, execute transactions, and provide experience, cooperation via the use of BOTOL’s Machines, BOTOL App and Products, Services. This ensures primary payment confirmation, transaction confirmation and reward distribution;

• Perform internal activities necessary to fix and resolve software errors, research, analyze, and test user behavior trends and platform activity;

• Enable interaction between BOTOL and Users, and among Users themselves;

• Personalize Users’ experience on the Machines and BOTOL App, such as identifying user preferences and suggesting related products or services;

• Operate, protect, upgrade, and optimize the Machines, BOTOL App and Products, Services, as well as improve and adjust the experience of Users on the Machines, BOTOL App;

• Monitor Machines and BOTOL App usage;

• Develop promotional policies, marketing, and promotion of Machines, BOTOL App and Products, Services;

• Send important updates about Data Subjects’ account and Products, Services, such as changes to terms of service, privacy policy updates, and security warnings;

• Survey purposes;

• Other purposes that are appropriate and related to the use of BOTOL’s Machines, BOTOL App and Products, Services;

• Allow BOTOL’s partners/ services providers to manage and allocate resources; and

• Facilitate the process of handling Personal Data for purposes related to providing Products Services offered by BOTOL.

 

1. Safety and Security

BOTOL use of Data Subjects’ Personal Data to ensure the safety and security of the Machines, BOTOL App and Products, Services and for all Users. This includes:

• Detecting and preventing mistakes, fraud, crime, or unlawful activities during the provision and use of the Machines, BOTOL App and Products, Services of BOTOL;

• Investigating any reported incidents, complaints, or potential violations arising from the use of Machines, BOTOL App and Products, Services of BOTOL; and

• Protecting the confidentiality or integrity of the Products, Services of BOTOL on the Machines and BOTOL App and any means or devices used to provide Products, Services to Users.

 

1. Research, Development, and Security

 

• BOTOL may use the Personal Data that BOTOL collect for testing, research, analysis, and Product, Services development such as improve the Machines and BOTOL Application performance, functionality, and reliability. This allows BOTOL to understand and analyze of Data Subjects’ needs and preferences, protect Data Subjects’ personal data, enhance safety and security for BOTOL’s  Products, Services, update existing features, develop new features, products, and services based on feedback and behavior, and enable the development of financial solutions.

 

1. Legal Purposes
    

• BOTOL may use the Personal Data that BOTOL collect for legal purposes, such as (i) to enforce BOTOL’s policies, including terms of service and policies privacy; (ii) to investigate and resolve complaints or disputes, detect/prevent/prosecute crimes, (iii) comply with obligations under current Applicable Laws; (iv) disclose to legal advisors, disclose to and/or assist Competent Authorities if believe it is necessary to protect the rights, property or safety of BOTOL, Users or the public or if BOTOL suspect that Data Subjects are engaged in illegal activities, suspected fraud or violation of BOTOL’s terms of service; or (v) when required by legal advisors, relevant laws, court orders, subpoenas or requests from Competent Authorities with jurisdiction, either locally or internationally.

 

1. Marketing and Promotion
    

BOTOL may use Personal Data to send Data Subjects marketing information related to personalized products or services (which Data Subjects may find interesting or relevant to Data Subjects based on Users’ account information) or products, services, events, or promotional programs from BOTOL’s partners and advertisers, as well as to notify, invite, and manage Data Subjects’ participation in BOTOL’s events or activities.

 

• Content: Send Data Subjects special offers, which Data Subjects may find interesting or relevant through service suggestions, including but not limited to programs, promotional and marketing messages, gift programs, discounts, purchase offers;

• Methods and Formats: Send Data Subjects notifications, newsletters, updates, messages, invitations, promotional materials, privileges, holiday greetings, etc.;

• Frequency of Product Recommendations: Regularly according to marketing and promotional programs that BOTOL carry out and register with the Competent Authorities.

 

Data Subjects have the option to opt-out of receiving marketing and promotional communications and reports at any time. Data Subjects can manage Data Subjects’ communication preferences in Data Subjects’ account settings or follow the unsubscribe instructions provided in BOTOL’s emails.

 

In cases where BOTOL Processes Data Subjects’ Personal Data for purposes beyond those listed in this Article 3 of the Privacy Policy, BOTOL will require Data Subjects’ prior consent at each point in time, unless otherwise stipulated by the Applicable Laws or requested by the Competent Authorities.

 

1. Individuals or organizations that may have access to the Personal Data of Data Subjects

 

BOTOL shall not share or grant access to the Personal Data of Data Subjects to any third party except those related to the Purposes of Processing the Personal Data as listed below. By acceptance of Consent of Data Subjects from time to time, Data Subjects hereby agrees to allow BOTOL to share Personal Data with the following third parties as follows:

 

1. Subsidiaries, associates, divisions and Affiliates of BOTOL in case of sharing data resources with each other, such as infrastructure and technology, and for the Purposes of Processing Personal Data in accordance with this Privacy Policy;

 

1. Suppliers, consulting experts, marketing partners, research companies and service providers or other business partners, including: technical support providers; email service providers; payment services providers; cloud storage provider; customer service providers; advertising and marketing partners; data analytics providers; research partners, including those conducting surveys or research projects cooperating with BOTOL or on BOTOL's behalf; and other partners involved in providing Products, Services of BOTOL to Data Subjects; and/ or

 

1. Legal advisors; courts and arbitrators on case by case basis, other organizations and individuals as required or permitted by the Applicable Laws or at the request of the Competent Authorities.

 

1. Data security

 

BOTOL is committed to ensuring the security and protection of Data Subjects’ data. To protect Data Subjects’ data, BOTOL deploys a range of security measures designed to protect against unauthorized access permission, disclosure, alteration or destruction of Data Subjects’ data. BOTOL’s security measures include including but not limited to:

 

1. Encryption: BOTOL uses advanced encryption technologies to protect Data Subjects’ data both in transmission and in storage. This means when Data Subjects type, send or access Data Subjects’ data will be encrypted to prevent unauthorized access during transmission.

2. Access Control: Access to Data Subjects’ data is limited to authorized persons. BOTOL uses access control mechanisms strict, including multi-factor authentication and role-based access control, to ensure that only people with a legitimate need can access Data Subjects’ data.

3. Regular security testing: BOTOL conducts security testing and assessments regularly to identify and address potential vulnerabilities in BOTOL’s systems. This includes periodic vulnerability scanning, penetration testing, and compliance testing so as to ensure BOTOL’s security measures are effective.

4. Secure Storage: BOTOL’s applications and data are stored on security servers that are protected by advanced security protocols and monitoring systems. This incubation is located in data centers with strong physical security measures prevent unauthorized access.

5. Firewalls and Intrusion Detection Systems: BOTOL deploy firewalls and Intrusion detection system to monitor and protect BOTOL’s network from malicious activities harmful. These systems help BOTOL detect and respond to potential security threats hidden in real time.

6. Anonymization and data minimization: Wherever possible, BOTOL anonymizes and minimizes the data BOTOL collects and stores. This reduces the risk of exposure in the event of a data breach and ensures that only essential information is kept again.

7. Employee training: BOTOL’s employees receive regular training on these best practices on data security and privacy policies to ensure they are aware be responsible for protecting Data Subjects’ data. BOTOL nurtures culture security awareness in Data Subjects’ organization.

 

Despite best efforts to implement these security measures, it is important to understand that no security system is completely impenetrable. In spite of BOTOL strive to protect Data Subjects’ data but BOTOL cannot guarantee absolute security to BOTOL’s databases or Data Subjects’ data will not be intercepted in transmission to them via the Internet. Thus BOTOL shall not be liable for risks of data transmission and damage incurred during the process of transmission, except in the case of faults or violations of the Applicable Laws committed by BOTOL.

 

1. Data storage

 

Personal Data of Data Subjects shall be archived within a certain period necessary for implementing the Purposes above, or as required by the Applicable Laws. BOTOL’s data retention includes:

 

1. Active account management: BOTOL store Data Subjects’ Personal Data as long as Data Subjects’ account remains active. This allows BOTOL to deliver ongoing access to Data Subjects to BOTOL’s Products, Services, maintain Data Subjects’ account settings and provide customer support.

2. Providing Products, Services: BOTOL retains data for a period of time necessary to provide Data Subjects with the Products, Services Data Subjects have requested. This includes handling the management of Data Subjects’ rewards and delivering personalized content and recommendations chemistry.

3. Legal Compliance: BOTOL may retain certain data for complying with its legal obligations, such as tax, accounting and regulatory requirements determined. For example, transaction records may be kept for a certain period of time in response audit and financial reporting obligations.

4. Dispute Resolution: BOTOL retain Data Subjects’ data as necessary to resolve disputes, enforce BOTOL’s agreements and protect BOTOL’s legal rights. This includes retaining data related to customer support requests, legal claims and other potential issues that may arise.

5. Fraud prevention and security: To ensure security for Users and BOTOL’s operation, BOTOL may retain certain data for detection, prevention and minimize fraud, abuse and security threats. This helps BOTOL maintain the integrity and security of its platform.

6. Data Minimization: BOTOL regularly reviews Personal Data that BOTOL holds and takes steps to remove or hide the data list is no longer needed for the purpose of collecting that data. This ensures that BOTOL does not retain data for longer than required.

7. Data Subjects-initiated deletion: Data Subjects have the right to request deletion of Data Subjects’ Personal Data. If Data Subjects choose to delete Data Subjects’ account or specific data, BOTOL will process the request to Data Subjects in accordance with Applicable Laws and BOTOL’s internal policies. Please note that some data may be retained if required by law or for reasonable business purposes.

 

1. Rights of Data Subjects to Personal Data

 

Depending on circumstances and the provisions of the Applicable Laws, Data Subjects has certain rights toward their Personal Data. Data Subjects have the following right:

 

1. Right to request access to, or be provided with, a copy of Data Subjects’ Personal Data that BOTOL are Processing, together with information about the nature, processing and sharing of such Personal Data;

2. The right to request the edition of incorrect content of Data Subjects’ Personal Data that BOTOL are processing.

3. The right to withdraw consent.

4. The right to request the erasure of data.

5. The right to restrict of data processing.

6. The right to object to data processing.

7. The right to complaint, denounce, initiate lawsuits.

8. The right to claim damage.

9. The right to self-protection.

 

However, the choosing not to share the Personal Data of Data Subjects with BOTOL, or withdrawing consent, requesting the erasure of Personal Data, objecting to the process of Personal Data of Data Subjects may lead to the fact that BOTOL are unable to take all necessary actions to obtain the Purposes of processing as described in Article 3 of this Privacy Policy or result in the failure of BOTOL to perform their relevant obligations to Data Subjects in certain circumstances.

 

Note: If Data Subjects wants to request for implementation of their rights, Data Subjects may contact BOTOL via Contact BOTOL under Article 10 of this Privacy Policy for specific instructions. BOTOL shall first screen and verify all requests. In order to verify the identity and/or competency to fulfill Data Subjects’ requests, BOTOL may request the Data Subjects to provide information or documents supporting the request for verification. After verification, BOTOL will process the Data Subjects’ requests within the time limit as provided under Applicable Laws. 

BOTOL can reject the request to delete Personal Data of Data Subjects in the following circumstances:

 

1. The relevant law stipulates that data deletion is not allowed;

 

1. Personal Data is processed by Competent Authorities for the purpose of serving the operation of Competent Authorities in accordance with the relevant laws;

 

1. Personal Data has been made public in accordance with the relevant laws;

 

1. Personal Data is processed to serve legal requirements, scientific research and statistics as prescribed by the relevant laws;

 

1. In case of national defense and security, social order and safety, major disasters or dangerous epidemics; when there is a threat to national security or defense but not to the extent of declaring a state of emergency; prevention and prevention of riots, insanity, prevention of crime and violations of the relevant laws; or

 

1. Response to an emergency that threatens the life, health, or safety of Data Subjects or another individual.

 

1. Obligations of Data Subject toward their Personal Data

 

According to the Applicable Laws, Data Subjects have the following obligations:

 

1. Provide full and accurate Personal Data as requested by BOTOL when agreeing to allow BOTOL to process Personal Data;

 

1. Take necessary measures to self-protect their Personal Data. If the Personal Data of Data Subjects is revealed because of negligence or any other security fault on the part of themselves, Data Subject must take the risks and damage incurred; and

 

1. Comply with regulations on the protection of Personal Data and participate in preventing and combating violations of regulations on the protection of Personal Data.

 

 

1. Changes to this Privacy Policy

 

BOTOL is committed to comply with the prevailing Applicable Laws thus it may require BOTOL to update this Privacy Policy from time to time. This section outlines how BOTOL handles changes to the Privacy Policy and how BOTOL will notify Data Subjects of these changes.

 

1. Periodical updates: BOTOL may update this Privacy Policy periodically (if any) to reflect changes in practice, legal requirements or operational needs. These updates help ensure that BOTOL’s Privacy Policy is always updated, transparent and comprehensive.

 

1. Material Changes: With respect to amendments, modifications, and supplementations in this Privacy Policy relating to the change of type of the processed Personal Data, Purposes of processing, Data Subjects of which Personal Data is processed, the rights and obligations of Data Subjects to their Personal Data, BOTOL shall contact Data Subjects via Notification method below to obtain Data Subjects’ consent to these changes.

 

1. Notification method: BOTOL will notify Data Subjects of important changes through one or more following methods:

   • In-app notifications: BOTOL will display in-app notifications BOTOL App, notify Data Subjects of changes and provide a link to the Updated Privacy Policy; or

   • Announcements on the site: BOTOL will post notices on the website, highlighting changes and linking to the Updated Privacy Policy.

 

1. Contact BOTOL

 

BOTOL appreciate Data Subjects’ feedback and are ready to assist Data Subjects if Data Subjects have any questions or concerns regarding this Privacy Policy or BOTOL’s Products, Services. Our dedicated support is always ready to provide necessary assistance and resolve any issues related to privacy. Data Subjects can contact BOTOL through the following channels:

 

1. Email support: For general questions, privacy concerns or to exercise Data Subjects’ data protection rights, Data Subjects can contact BOTOL by email at Email: admin@botol-dash.com . Please include a detailed description of Data Subjects’ problem or request helps BOTOL respond more effectively.

 

1. In-app support: Data Subjects can also contact BOTOL directly through BOTOL App. Navigate to the "Support" or "Help" section in the App, where Data Subjects may find options to submit a support request or chat with a customer service representative.

 

1. Feedback and Suggestions: BOTOL welcome feedback and suggestions regarding how BOTOL can improve BOTOL’s services and security practices. Please share thoughts to BOTOL via email or through the feedback feature in BOTOL App.

 

1. Implementation provisions

2. This Privacy Policy is effective on 18 September 2023 and is construed and governed in accordance with the Applicable Laws.

3. Any matters related to the protection of Personal Data that are not stipulated in this Privacy Policy and/or where there is any inconsistency between this Privacy Policy and the Applicable Laws from time to time, the Applicable Laws shall prevail.