Privacy Policy

1. Data controller and processor

Spinning International Joint Stock Company, of Unit 3.04, 3rd Floor, Commercial - Service - Office - Officetel Area, 38 Truong Quoc Dung, Phu Nhuan Ward, Ho Chi Minh City, Vietnam, tax code 0318830316, is the controller and processor of personal data collected through the channels above.

2. What we collect

Depending on how you contact us, we may collect:

• Your name, phone number / Zalo and email address.
• Your investment needs: site status, intended area, package of interest, prior franchise experience, capital range and expected timing.
• How you heard of Đô Thị, and campaign parameters in the link (utm_source, utm_medium, utm_campaign) if present.
• Your conversation with the Đô chat assistant; on Zalo, Facebook and Instagram, also the account identifier and display name the platform provides (the display name is only used so the assistant can address you). When you comment under a Đô Thị post on Facebook or Instagram: your display name, the comment text and the post ID (any phone number or email written in a comment is not used and is hidden from the stored content).
• Information you give our advisors directly (by hotline, at events or seminars) and notes of the consultation.
• At the confidentiality stage: the details on the Non-Disclosure Agreement (NDA) and the scan of the signed NDA.

3. Why we use it

We do not sell your personal data, and we do not process it for any purpose beyond these without your consent.

• To contact you about the franchise opportunity you asked about.
• To assign an advisor and track follow-up.
• To send the NDA and the franchise dossier and to carry out pre-contract steps at your request.
• To answer questions through the chat assistant, including translating into your language, and to assess advisory quality in aggregate.
• Internal, aggregated statistics on marketing channel performance.
• To email you about promotions, events and franchise news — ONLY if you tick the separate consent for this purpose.

4. Legal basis: your consent

We process your data only with your consent: ticking the consent box on the enquiry form, or pressing "I agree" when the chat assistant asks before collecting contact details. Silence or no response is never taken as consent.

Consent to promotional email is a separate, optional choice and does not affect your consultation.

The time and channel of your consent are recorded. If you do not agree, the chat assistant does not keep your contact details.

5. Withdrawing consent

You can withdraw consent at any time by emailing info@spinint.com.vn or calling +84 862 222 600. For promotional email, you can also reply "UNSUBSCRIBE" to the email.

Withdrawal does not affect processing lawfully carried out before it. After withdrawal we stop processing for that purpose and delete or anonymise the data, except what the law requires us to keep.

6. Who sees it and our processors

Your data is accessible only to:

• Đô Thị sales, administration and management staff, under role-based access (each person sees only their part of the work).
• Zalo (VNG Corporation) — receiving and sending messages on Zalo OA, and notifying advisors.
• Meta Platforms, Inc. — receiving and sending messages when you contact us on Facebook Messenger or Instagram, receiving comments under Đô Thị posts and sending replies (publicly under the comment, or one private message).
• Google LLC — company email and document storage (Google Workspace, Google Drive), and the Gemini AI models (paid tier) that help the chat assistant translate, compose replies from approved content and summarise conversations. Content is sent for processing on request and is not used to improve or train Google's products, under the paid-tier terms.
• Our hosting and infrastructure providers (cloud servers and database).

7. Transfers outside Vietnam

The system's application servers and database are located in Japan (Tokyo); Meta and Google process data on their own servers, mainly in the United States. Your data is therefore transferred to and stored outside Vietnam.

Such transfers rely on your consent, are made to parties committed to protecting the data, and we prepare and keep an overseas-transfer impact assessment dossier as required by Decree 13/2023/NĐ-CP.

8. Storage and retention

Data is held on access-controlled cloud infrastructure, and access to customer records is logged.

Enquiry records are kept for up to 24 months from your last contact. Records that ended without a signed contract are automatically anonymised when that period expires (name, phone, email, address, notes, documents and the attached chat removed).

The content of chat-assistant conversations not linked to an enquiry record (including any comment that led to the conversation) is deleted 24 months after the last message; only non-identifying statistics are kept.

If you sign a franchise agreement, the related data is kept for the term of the agreement and the record-keeping period required by law.

Consent to promotional email lasts until you withdraw it.

The database has automatic backups for recovery after an incident; backups are kept for up to 1 day, so deleted or anonymised data may remain in a backup for at most 1 day before it disappears.

9. Your rights under Decree 13/2023/NĐ-CP

You have the following rights over your personal data:

• To be informed about processing.
• To consent, or not, to processing.
• To access, view and correct your data.
• To withdraw consent.
• To erasure.
• To restrict processing.
• To obtain a copy of your data.
• To object to processing.
• To complain, report, or bring legal proceedings.
• To claim compensation for damage.
• To self-protection as provided by law.

10. How to exercise your rights

Email info@spinint.com.vn or call +84 862 222 600. We respond within 72 hours of receiving a valid request.

We may need to verify your identity before acting, to protect your data.

11. Security

We apply appropriate technical and organisational measures: role-based access, encryption in transit, NDA documents stored separately and visible only to authorised staff, and audit logging of access to customer records.

No system is perfectly secure. If an incident affects personal data, we will notify you and the competent authority as required.

12. Cookies and browser storage

The site uses a strictly necessary cookie to keep staff signed in to the internal system. It sets no third-party advertising cookies.

When you use the chat assistant on the website, your browser stores a random identifier so the conversation can continue on your next visit. You can remove it by clearing the site's data in your browser.

If you arrive through a link with campaign parameters, those are stored with your enquiry for internal statistics.

13. Children's data

Our franchise channels are aimed at adult investors and do not knowingly collect data from anyone under 16. If we learn we have, we delete it promptly once told.

14. Changes to this policy

We may update this policy. The date at the top shows the latest version. Material changes, especially to the purposes of processing, will be announced on the site and consent sought again where needed.