Privacy Policy

I. WHO ARE WE? 

Private HAUS Company Limited – 1010 club, No. 1 Dinh Tien Hoang Xuan Huong Lake, Lam Dong, Viet Nam, is the owner and operator of this website (1010.club) (Site),

You can contact us as indicated under the Contact section below. The data controller responsible for your personal data is Private HAUS Company Limited with whom you contract as a customer, member or membership applicant. We take the privacy of applicants and our members and their guests very seriously. If you do have any questions or concerns regarding this policy or how we may use your personal data then please do contact us as described in the Contact section below and we will endeavour to address this.

 

II. WHAT THIS PRIVACY POLICY IS FOR 

This privacy policy (Privacy Policy) applies to personal data that we collect from you as a user of this Site or as a membership applicant, member or customer (you or your being interpreted accordingly). It is an integral part of the agreement/contract signed between you and us and to provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws in Vietnam.

By providing your information or by ticking the consent checkbox on our Site, you are deemed to have agreed to the collection and processing of your personal data in accordance with this Privacy Policy, so please read it carefully.

 

III. PERSONAL DATA WE COLLECT

We collect the following personal data about you:

  • Membership Application: The personal details you provide when submitting a membership application. This includes your [name, address, e-mail address; business address and phone number; gender and date of birth; country; a picture of yourself; information about your work and other information that you select to provide to support your application]. We may also collect information about your payments to our payment service providers, that we require for the purpose of recording and processing your membership application (and administering your membership). For further details please also refer to the section below headed Payment Information.
  • Reservation Information: Guest information, such as your first and last name, email address, billing and payment information (for further details please also refer to the section below headed Payment Information). Personal data collected in relation to reservations will be processed in accordance with a privacy policy provided at the time of requesting a reservation so please ensure that you read our privacy notice on the reservation website that we may provide to you when we collect or process your personal data.
  • Financial Information: Wherever possible, for any payment requirements you will be encouraged to use our secure third-party payment provider which is currently PaymentGateway (for further details please also refer to the section below headed Payment Information). We do not directly receive or retain any debit/credit card and bank account information provided by you.
  • Other Information: Personal details you choose to give when corresponding with us by phone or e-mail, participating in user/customer/member surveys or otherwise visiting and interacting with this Site or any other websites we operate, and personal data that you provide to us when you visit one of our clubs or other premises. We can also combine personal data that you provide to us with other information we collect about you when you make a reservation through third-party services such as online restaurant- reservation or travel fare aggregator websites, as necessary to process your requests.

 

IV. AUTOMATICALLY COLLECTED PERSONAL DATA 

  • Log Data: When you visit our Site, our servers record information (log data), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (IP) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.
  • Our Site uses cookies (small files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Site and allows us to improve its features. For detailed information on the cookies and similar technologies we use, please see our Cookie Policy.

 

V. WHERE YOUR PERSONAL DATA IS STORED 

Your personal data will be stored in ‘Salesforce’, a cloud-based customer relationship management platform. Salesforice is a GDPR compliant two-sided secure platform. Data also stored in custom 1010 system.

 

VI. HOW WE USE YOUR PERSONAL DATA 

We use your personal data in the following ways:

  • To acknowledge, confirm and deal with your membership application (and where necessary put you on our waiting list). Such use of your data is necessary in order to implement your request to become a member.
  • Where you are a member, provide you with membership services, administer your membership account and contact you regarding your use of the services. Such use is necessary to respond to or implement your request and for the performance of the contract between you and us.
  • To contact you in connection with user/customer/member surveys and to provide postal communications about us and our services which we think will be of interest to you and to use any information you choose to submit in response, provided that you gave us your consent to being contacted in this way at the time you provided us with the personal data.

As necessary for certain legitimate business interests, which include but not limited to the following:/ Chúng tôi cũng xử lý dữ liệu cá nhân khi cần thiết cho các mục đích kinh doanh hợp pháp, bao gồm nhưng không giới hạn ở:

  • Where we are asked to deal with any enquiries or complaints you or your guests may make.
  • To administer our Site, to better understand how visitors interact with our websites and ensure that our Site is presented in the most effective manner for you and for your computer/device.
  • To conduct analytics to inform our marketing strategy and enable us to enhance and personalise the experience we offer to our members and our communications, including by creating customer or member profiles to enable personalised direct marketing communications.
  • With your consent (through your action expressing consent on the relevant feature of this Site), to share personal data among our affiliated businesses for administrative purposes only, such as where they are assisting us in providing our membership services or our sales and marketing activities.
  • We may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business purposes, including sharing it with our current and prospective members, business partners, our affiliated businesses, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behaviour.
  • For internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site, network and information systems secure.

In order to:

  • Comply with legal obligations;
  • Respond to requests from competent State authorities;
  • Protect and defend our legitimate rights and benefits, safety or property, and/or that of our affiliated businesses, you or others in case of violations and/or emergency; and 
  • Respond to emergencies or threats to national security that have yet to escalate to the level of a declared emergency; to prevent and combat riots, terrorism, crimes, and law violations;
  • Carry out the agreement between you and a relevant agency, organization, or individual according to the laws;
  • Serve other cases prescribed by laws;

We may use your personal data for other purposes which you have consented to at the time of providing your data unless you subsequently notify us that you withdraw that consent, following which we will stop using that data unless otherwise permitted to do so under this Privacy Policy.

As used in this Privacy Policy, legitimate interests means the interests of 1010 Club in conducting and managing our organisation. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see Your Data Protection Rights section below).

 

VII. DISCLOSURE OF YOUR PERSONAL DATA 

We may share your personal data with third parties in the following situations:/Chúng tôi có thể chia sẻ dữ liệu cá nhân của Quý khách với bên thứ ba trong những trường hợp dưới đây.

  • The network of Private Haus Company, such as parent company, subsidiary company, affiliated company of the Private HAUS Company: To provide you with the best possible experiences, we may disclosure your personal data with these companies so that they can access, process, or store your personal data in the course of performing their duties to us.
  • Service Providers: Private HAUS Company, like many businesses, sometimes hires selected third parties who act on our behalf to support our operations, such as (i) card processing or payment services (see the section below headed Payment Information), (ii) credit reference agencies to protect against possible fraud, (iii) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide membership services and other goods/services available on this Site or to members, (iv) web analytics providers, (v) providers of digital advertising services and (vi) providers of CRM, marketing and sales software solutions. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide. We can, on request. provide further details of our current and historical providers who may receive or have received your personal data for such purposes.
  • Business Transfers: if we sell our business or all or a material part of our company assets are acquired by a third party, personal data held by us about our members, membership applicants or customers may be one of the transferred assets.
  • Administrative and Legal Reasons: if we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process. (ii) to enforce the Club Rules or other applicable contract terms that you are subject to or (iii) to protect us, our members, membership applicants, or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.

 

VIII. PAYMENT INFORMATION 

Any credit/debit card payments and other payments you make through our Site  or in connection with your use of our services, including but not limited to payment for room hire deposits and pre-ticketed event payments, will be processed by our third-party payment provider, ‘Stripe’, and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Stripe’s Privacy Policy can be found here. Please note that we do not ourselves directly process or store the debit/credit card data that you submit and we are not responsible for any content or the legal compliance of Stripe’s Privacy Policy.

We may arrange that card or payment data you submit in support of a membership application or subscription fee is, where appropriate (such as where you have asked us to set up a standing order, direct debit or other repeat payment arrangement), stored by our third-party payment provider for the purpose of processing your application, initiating your membership and collecting your subscription fees if your initial application is successful (or if you are put on to a membership waiting list, please note that this data may be stored for later use to initiate your membership and subscription).

 

IX. SECURITY

We has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite our best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions or as they are obliged to do by law, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach in accordance with the laws.

 

X. YOUR DATA PROTECTION RIGHTS 

We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. In particular, we retain membership records for 6 years after expiration or termination of your membership. We retain information submitted through the Site and the other websites we operate for [X] years following account closure or contact with you, as applicable.

When you consent to receive marketing communications, we will keep your data until you unsubscribe.

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data, applicable legal requirements or operational retention needs, and whether we can achieve those purposes through other means always provided that such retention period, purpose and means are complied with the applicable laws.

Upon expiry of the applicable retention period we will securely erase, destroy, de-identify your personal data in accordance with applicable laws and regulations so that it can no longer be associated with you, in which case it is no longer personal data.

 

XI. YOUR PERSONAL DATA PROTECTION RIGHTS 

WHAT ARE THE DATA PROTECTION RIGHTS IN VIETNAM 

Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the laws on protection of personal data, you have the following rights in relation to your personal data:

  • Right to know: You are entitled to know information on the processing of your personal data.
  • Right to consent: You are entitled to consent or refuse to consent to the processing of your personal data, except in cases where data processing does not require your consent under Vietnamese law.
  • Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details such as the purpose of the data processing. If you require additional copies, we may need to charge a reasonable fee for printing and delivery to you.
  • Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
  • Right to data provision: You are entitled to request personal data controllers or personal data controlling and processing parties to provide the former with your personal data, unless otherwise provided for by the Vietnamese law.
  • Right to erasure: You may ask us to delete or remove your personal data, such as where our legal basis for the processing is your consent and you withdraw consent. If we shared your personal data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data with so you can contact them directly.
  • Right to restrict processing: You are entitled to request restriction of the processing of your personal data, unless otherwise provided for by law. You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
  • Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will provide you with your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
  • Right to object: You may ask us at any time to stop processing your personal data, and we will do so.
  • Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
  • Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you are entitled to file complaints or denunciations or initiate lawsuits in accordance with Vietnamese law.
  • Right to claim compensation for damage: You are entitled to claim compensation for damage in accordance with law upon occurrence of a violation of regulations on protection of your personal data, unless otherwise agreed upon by the parties or otherwise provided for by Vietnamese law.
  • Right to self-protection: You are entitled to self-protection in accordance with the Vietnamese law, or request competent agencies or organizations to take measures to protect your personal data in accordance with the Vietnamese laws.

If you wish to exercise any of these rights please contact us as described in the Contact section below. We may also need to ask you for further information to verify whether you are the subject of the personal data in your request before we can respond to any request.

 

XII. YOUR PERSONAL DATA PROTECTION OBLIGATIONS 

  • To protect your personal data by yourself; to request related organizations and individuals to protect your personal data.
  • To respect and protect personal data of others.
  • To provide adequate and accurate personal data when giving consent to the processing of your personal data.
  • Other responsibilities as provided by law.

 

XIII. PRINCIPLES GOVERNING YOUR RIGHTS AND OBLIGATIONS 

When performing your rights and obligations, you, as a subject of personal data, shall ensure your compliance with the following principles:

  • To comply with the laws, contractual obligations. The exercise of your rights and obligations as a personal data subject must serve to protect your legitimate rights and interests;
  • To refrain from obstructing or hindering the implementation of legal rights and obligations of the personal data controlling parties, personal data processing and controlling parties, and personal data processing parties that are mentioned herein;
  • To refrain from infringing on the legitimate rights and benefits of the State, ours, and other agencies, organizations, and individuals.

 

XIV. REFUSE YOUR REQUEST 

We may refuse your request if it fails to comply with the principles as prescribed in Article 13 above.

 

XV. WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

XVI. THIRD-PARTY LINKS 

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

 

XVII. CHANGES TO OUR PRIVACY POLICY 

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, we will notify you of any material or substantive changes to this Privacy Policy.

 

XVIII. CONTACT 

Questions, comments or requests regarding this Privacy Policy should be addressed to privacy@1010.club.

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