RC GOLD PRIVACY POLICY

Effective Date: 7th August 2025

Last Updated: 7th August 2025

1. Introduction

Welcome to RC GOLD, the loyalty application for Cityzoo Limited Company ("we," "us," or "our"). We are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use our RC GOLD mobile application and related services.

This Privacy Policy complies with Vietnamese Decree 13/2023/ND-CP on Personal Data Protection, the Law on Cybersecurity 2018, and international standards including the General Data Protection Regulation (GDPR) where applicable.

2. Information We Collect

2.1 Personal Information

• Account Information: Name, email address, phone number, date of birth

• Profile Information: Pet information (name, breed, age, dietary preferences)

• Contact Details: Shipping and billing addresses

• Identification: Government-issued ID numbers when required by law

2.2 Transaction Data

• Product Scan History and loyalty points balance

• Payment information (processed securely through third-party payment processors)

• Redemption history and rewards claimed

• Store visit frequency and preferences

2.3 Technical Information

• Device information (model, operating system, unique device identifiers)

• App usage data and analytics

• Location data (with your explicit consent)

• Log files, cookies, and similar technologies

2.4 Communication Data

• Customer service interactions

• Survey responses and feedback

• Marketing communication preferences

3. Legal Basis for Processing (Vietnamese and International Law)

Under Vietnamese Decree 13/2023/ND-CP and international standards, we process your personal data based on:

• Consent: When you explicitly agree to data processing

• Contract Performance: To provide loyalty services and fulfill transactions

• Legitimate Interest: For business operations, fraud prevention, and service improvement

• Legal Obligation: To comply with Vietnamese tax, accounting, and regulatory requirements

4. How We Use Your Information

4.1 Primary Purposes

• Manage your RC GOLD loyalty account and points

• Process transactions and deliver products/services

• Provide customer support and respond to inquiries

• Send account-related notifications and updates

4.2 Marketing and Personalization

• Send promotional offers and product recommendations (with consent)

• Customize app content based on your preferences

• Conduct market research and surveys

• Analyze usage patterns to improve our services

4.3 Legal and Security Purposes

• Comply with Vietnamese legal obligations

• Prevent fraud and ensure platform security

• Resolve disputes and enforce our terms

• Maintain accurate business records

5. Data Sharing and Disclosure

5.1 We May Share Your Information With:

• Service Providers: Payment processors, delivery companies, IT service providers

• Business Partners: Authorized retailers and promotional partners

• Legal Authorities: When required by Vietnamese law or court orders

• Professional Advisors: Legal, accounting, and consulting services

5.2 We Do NOT Sell Your Personal Data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

5.3 International Transfers

If we transfer data outside Vietnam, we ensure adequate protection through:

• European Commission adequacy decisions

• Standard contractual clauses

• Binding corporate rules

• Your explicit consent

6. Your Rights Under Vietnamese and International Law

6.1 Access and Information Rights

• Request access to your personal data

• Obtain information about how we process your data

• Receive a copy of your data in a portable format

6.2 Correction and Update Rights

• Correct inaccurate personal information

• Update incomplete data

• Modify your communication preferences

6.3 Deletion Rights

• Request deletion of your personal data

• Withdraw consent for processing

• Close your RC GOLD account

6.4 Objection and Restriction Rights

• Object to processing based on legitimate interest

• Restrict processing in certain circumstances

• Opt-out of marketing communications

6.5 Complaint Rights

• File complaints with Vietnamese data protection authorities

• Contact relevant supervisory authorities in your jurisdiction

7. Data Security and Protection

7.1 Security Measures

• Industry-standard encryption for data transmission and storage

• Multi-factor authentication for account access

• Regular security audits and vulnerability assessments

• Staff training on data protection principles

7.2 Data Breach Procedures

• Immediate containment and assessment of any security incidents

• Notification to authorities within 72 hours as required by law

• User notification when legally required or when high risk exists

8. Data Retention

8.1 Retention Periods

• Account Data: Retained while your account is active plus 5 years after closure

• Transaction Records: 10 years as required by Vietnamese accounting law

• Marketing Data: Until consent is withdrawn

• Legal Compliance Data: As required by applicable laws

8.2 Deletion Process

Data is securely deleted or anonymized when retention periods expire, unless legal obligations require longer storage.

9. Cookies and Tracking Technologies

9.1 Types of Technologies Used

• Essential Cookies: Required for app functionality

• Analytics Cookies: To understand app usage and performance

• Advertising Cookies: For personalized marketing (with consent)

9.2 Managing Preferences

You can control cookie settings through your device settings or app preferences. Note that disabling essential cookies may affect app functionality.

10. Children's Privacy

RC GOLD is not intended for children under 13 years old. We do not knowingly collect personal information from children without parental consent. If we discover we have collected such information, we will delete it promptly.

11. Third-Party Services

Our app may contain links to third-party services. We are not responsible for the privacy practices of these external services. We encourage you to review their privacy policies.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will:

• Notify users of material changes via app notification or email

• Post the updated policy with a new effective date

• Obtain consent for changes that expand data usage significantly

13. Contact Information

Customer Support

Email: marketing4@cityzoo.vn

Phone: 0834502000

Hours: Monday-Friday, 8:00 AM - 6:00 PM (Vietnam Time)

14. Governing Law

This Privacy Policy is governed by the laws of Vietnam. Any disputes will be resolved in Vietnamese courts, subject to applicable international agreements.

15. Languages

This Privacy Policy is available in Vietnamese and English. In case of discrepancies, the Vietnamese version shall prevail for users in Vietnam.

Acknowledgment

By using the RC GOLD application, you acknowledge that you have read, understood, and agree to this Privacy Policy.

Company Information

CITYZOO COMPANY LIMITED

Business Address: 146D4 Nguyen Van Huong Street, An Khanh Ward, Ho Chi Minh City, Viet Nam

Tax Code: 0301636007

This Privacy Policy was last updated on 7th August 2025. Please check regularly for updates.