Privacy Policy

Your privacy and the protection of your sensitive personal information are important to us. This Privacy Policy (the “Policy”) is a binding agreement between you and Homebase Management Company Limited, having enterprise registration certificate no. 0316086807, initial issued on 27 December 2019 by Department of Planning and Investment and its affiliated companies (“Homebase”), apply to your use of this website, any associated mobile Sites, applications, or platforms (“the “Site”). The terms, conditions, provisions and notices contained herein govern your use of the Site and the other products, features, apps, services, data, technologies and software offered by Homebase (together with the Site, the “Services”), except where we expressly state that separate terms (and not this Policy) apply.

1. Purposes for collecting Personal Data

1.1. Homebase will collect, process, use and transmit your personal data within the scope of the following specific purposes in accordance with the nature of the services provided to you.

1.1.1. Site Operation. To run the Site, fix bugs to make sure you always see the Site the way we intended, and monitor compliance with Homebase’s Terms and Conditions of Use, we screen all traffic to the Site and analyse data that is received by Homebase’s servers.

1.1.2. Domain And Network Security And User Authentication. To protect Homebase’s domains, detect unusual activities, and prevent security threats and protect the Site-visitors from unauthorised accesses (such as hackers), we screen all traffic to the Sites, and authenticate user log-in information using tokens to verify the details you provide to us and compare it with other available information, such us the credentials you have provided directly to Homebase or other platforms (such as Runtastic or Facebook) or information that is available in the public domain to ensure only “authorised” users have access to the Sites.

1.1.3. Fraud Detection. Homebase combine the information you provide to us with other information we obtain through Homebase’s third-party risk and fraud prevention service providers to ensure you are eligible to use the Services. This means depending on the outcome of the analysis of your information, we may reject your request of Services. This is a decision-making process that is required to conclude Homebase’s contracts with you.

1.1.4. Business Operational Analytics. Homebase need to know how we do as a business. This is in the interest of Homebase’s shareholders, board members, employees, and partners. For this purpose, we need to analyse different categories of information to understand how our products are selling in different markets, what are the popular features of our products, what worked and what didn’t in terms of Homebase’s marketing and advertising campaigns, product designs and distribution strategy, website design and overall user experience, so we can establish, implement, and evaluate Homebase’s business strategy. This includes analysing data to understand how users browse the Site to improve Homebase’s user experience design to make sure you will continue to use the Services and interact with us on the Site.

1.1.5. Customer Services. Homebase collect your Personal Data to tell you when the product you like is available upon your request and respond to your questions and concerns through various communications channels we make available to you.

1.1.6. Marketing Messages. Homebase send you marketing messages that we think you would be interested (“personalized”) to the telephone number or e-mail address you provide to us because you signed up to the Services. To send you “personalised” messages, observe your online (and sometimes, where applicable, offline) behaviour, and analyse your behaviour using analytics to best estimate what Services you might be interested in, and you can benefit from. This requires us to collect various categories of Personal Data from you. Homebase use different analytics tools to understand what your behaviour means in terms of your like and dislike of Homebase’s various Services, and to understand the impact (success rates) of the messages delivered to you.

1.1.7. Targeted Messages on Third-Party Advertising Platform. Homebase use third-party advertising platforms, such as Facebook, Google, YouTube, Instagram, etc. to send you messages that are targeted at you, based on your behaviour and browsing pattern, at specific times and locations of these platforms to increase the efficiency of Homebase’s advertising campaigns. Your Personal Data is shared with the third-party advertising platforms, and they will attempt to match your profile in their database to determine the optimal time and place (the page you are browsing) to show you an advertisement from Homebase. Homebase also need to analyse necessary information to understand the impact of our campaigns. If you don’t accept that we track you for this purpose, you will still see Homebase advertisements on other platforms at random.

1.1.8. Product Research and Development. Homebase conduct analysis to research improve our products and services. This includes asking you questions in surveys, asking you for feedback, asking you to test our products and provide us with a review, asking other service providers to conduct market and product research for us, try new technologies in our products that might collect Personal Data to stay ahead of the competition. Homebase retain this information based on Homebase’s “legitimate interest”, so by participating in any product review or survey, you agree that this is our legitimate interest. Where you wish to object to this legitimate interest, we will anonymise your information, so it is no longer Personal Data.

1.1.9. Supply of Services. To administer, process and supply Services and handle contracts related to Services. The processing of your Personal Data is necessary to enter into a contract with you or a legal entity you represent, to perform Homebase’s contractual obligations, to provide Services, to respond to requests from you, or to provide customer support.

1.1.10. Contact. To communicate with you in relation to Services through relevant channels such as email and chat and to answer your requests. This includes contacting you (or other necessary parties) to advise you of important safety-related information, or to notify first responders in the event of an accident involving Services. The processing of Personal Data is necessary (i) for performing Homebase’s contractual obligations, (ii) for Homebase’s legitimate interests and (iii) complying with Homebase’s relevant legal notification obligations.

1.1.11. Legal Obligation - Cooperation With Law Enforcement And Regulatory Authorities (Including Courts). When we are legally required to provide your Personal Data for national and public security reasons, crime prevention, investigation and prosecution, anti-money laundering, judicial proceedings, protection of other individuals’ rights and freedoms, and enforcement of civil claims, we will provide information as requested by the authorities or parties once we are satisfied that the request is mandated by law. Homebase may not be able to notify you if it is against the law to do so.

1.1.12. Collecting Your Device Information On Our HomebasebSite Using Cookies, Pixels, Tags, And Similar Technologies. When you visit the Site, we store data collectors such as cookies, tags, pixels, tag containers, beacons, among others, in your browser to obtain certain information about your current browsing session (“Cookies”). Cookies also enable Homebase’s website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period, so you don’t have to keep re-entering them whenever you come back to the Site or browse from one page to another. Homebase use Cookies for different purposes, which also mean they have different legal bases. Please review the information below to understand how we use different types of Cookies to fulfil different purposes.

1.2. Homebase will use the Personal Data you provide only for the specific purposes at the time of collection, except:

1.2.1. as required by police/prosecutorial/judicial/tax authorities or other competent authorities under legal proceedings;

1.2.2. as otherwise agreed upon by you in writing;

1.2.3. as specified by the applicable laws.

2. Categories of Personal Data

Homebase collect personal data about you that you provide while you use or any associated websites, desktop or mobile applications. Homebase collect most of this information during the registration and/or application process. Additional information may be gathered during your subsequent use of the Site, or other Services, or when we communicate with you via telephone, email, Homebase’s surveys, or other means. Categories of information you may provide to us include:

2.1. Identity information - includes: name [first, last, initials], date of birth, state ID information/ passport/ driver’s license, your tax code, citizenship status, marital status;

2.2. Contact information - includes: your phone number, shipping and billing address, e-mail address, messenger ID, social media handle, any other communication channel you have used to contact us for more information

2.3. Finance information - includes: information related to your financial ability (including your employment, if necessary) to use Services, provided to Homebase and its request;

2.4. Correspondence - includes: conversation we have when you contact customer service, the emails you write us about our products or services, the complaints you address to us via post, e-mail, fax, or call, notes we prepared on your feedback, call back from Homebase’s Customer Service to you, and any other communication between you and Homebase personnel. Homebase record all customer service calls for quality assurance purposes.

2.5. Social Media information - includes: information obtained through your interaction with us on various social media channels such as Facebook, Instagram, Google, etc., including: any social media information that is publicly available such as your social media handles, social media interactions and public postings, your “Likes” and other reactions, your social media connections, your photos that are public, or those you send to us by mentioning us or following Homebase’s social media posts by using “handles” or “hashtags”. Homebase obtain this information from the social media network (e.g. Facebook, Snapchat, Instagram, etc.) directly or indirectly through third-party agencies we have agreements with.

2.6. Device information - includes: information about your device or browser that give us an idea about your browsing behaviour or device usage. Your device information is collected by Homebase’s app, and your browser information is collected by Homebase’s cookies, tags, and pixels. This is often required for network security purposes. This includes, but not limited to: IP address, date and time of the visit, how long you remained on Homebase’s website, the referral URL (if you came to the Site via a different Site or an advertisement), the pages visited on the Site, your browser type, device type, versions, operating system.

3. Retention Period

3.1. Homebase will collect, process, use and retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

3.2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

4. Data Recipients

Homebase may disclose your Personal Data to the following parties (“Data Recipients”):

4.1. agents, sub-contractors, vendors or third party service providers, such as telecommunications, technical services, debt recovery, market research and data analytics services, valuation services, brokerage services;

4.2. any other party to whom you authorise us to disclose your personal data to;

4.3. Homebase’s marketing and business partners in connection with marketing promotions, products and services;

4.4. Homebase’s corporate clients;

4.5. amongst the Homebase corporate group and its related corporations or affiliates;

4.6. Homebase’s staffs, employees, consultants and professional advisers, such as Homebase’s lawyers and accountants;

4.7. banks, payment processing service providers, financial institutions and their respective service providers;

4.8. Homebase’s successor-in-title, prospective seller or buyer of any part or the whole of Homebase’s business, in connection with a merger, acquisition or sale of any part or the whole of the Homebase business; and

4.9. social media Sites

5. Your Rights upon Personal Data Processing

5.1. Request Access. You have the right to know whether Homebase is processing your data and which data are being processed.

5.2. Request Correction. You have the right to make sure we are using the accurate details about you;

5.3. Request Deletion. You have the right to ask us to delete your Personal Data if: a) we no longer need it for a specific purpose, for example, a contract or a legal requirement; or b) you withdraw the consent you provided if we asked for your consent when we collected your Personal Data; or c) if you object to Homebase’s use of your Personal Data based on legitimate interests we have identified, including direct marketing activities, unless we can demonstrate the compelling need of the legitimate interests;

5.4. Request Restriction. You have the right to stop us from doing certain things to your Personal Data when: a) you don’t think we are using the right Personal Data; b) you don't want us to delete your Personal Data, but you also don't think we are complying with the law; c) you want to make a legal complaint against us, but we want to delete the data; or d) you challenge Homebase’s explanation of Homebase’s use based on a "legitimate interest". When you successfully restrict how we use your Personal Data, we will only use your Personal Data with your consent, or unless it is required by law.

5.5. Withdraw Consent. When we use your Personal Data based on your consent, you have the right to change your mind and withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you.

5.6. Questions, Complaints, and Support. If you have any questions, complaints or need any support, can get in touch with Homebase by clicking here.

6. Miscellaneous

6.1. Applicable Law. This Privacy Policy shall be governed by and construed in accordance with Vietnamese law.

6.2. Sub-contracting and Assignment. Homebase reserves the right to sub-contract, transfer, assign or novate all or any of our rights and obligations under Homebase’s terms and conditions provided that your rights under Homebase’s terms and conditions are not affected. You may not sub-contract, assign or otherwise transfer any of your rights or obligations under the Homebase’s terms and conditions without our consent in writing.

6.3. Dispute Resolution. All or any disputes arising out or touching upon or in relation to the terms and conditions of this Privacy Policy, including the interpretation and validity of the terms thereof and the respective rights and obligations of the Parties, shall be settled amicably by mutual discussion, failing which any party can file a claim to the competent court.

6.4. Severability. You agree that if any part of this agreement is determined to be invalid or unenforceable pursuant to applicable law including, but not limited to, the warranty disclaimers and liability limitations set forth above, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of the agreement shall continue in effect.

6.5. Languages and Effectiveness. This Privacy Policy is made in both English and Vietnamese versions. In the event that there is any discrepancy between the Vietnamese version and the English version of this Agreement, the Vietnamese version shall prevail.