PERSONAL DATA PROTECTION POLICY

Morinaga Milk Industry Group and Elovi Vietnam Joint Stock Company (referred to as “we” or “Morinaga“) are responsible for following the current Electronic Transactions Law and other relevant laws of Vietnam about the protection of personal data in Vietnam (collectively referred to as the “Law“) and are committed to safeguarding your personal data.

This Personal Data Privacy Policy (“Policy“) is designed to assist you in understanding how we collect, use, disclose, store, and/or process the personal data you have provided to us in Vietnam. Please read this Policy carefully to understand our practices regarding your personal data and how we handle it. By accessing or using any official website, fan page, email, mobile application, phone call, message, or any other form of information exchange between you and Morinaga linked to this Policy, you express your agreement with the terms of this Policy.

We may update this Policy over time. Any changes we make to this Policy will be posted on our website, and your explicit and specific agreement will be obtained through written consent, verbal consent, checkbox consent, text message consent, selection of technical consent settings, or through other actions that demonstrate this.

This Policy includes:

1. Definition and Scope of Policy 
2. How is your data collected? 
3. What types of personal data do we collect from you? 
4. Why do we collect your data? 
5. Whom do we share your data with? 
6. How do we protect your data? 
7. Direct Marketing and Product Introduction 
8. Cookie 
9. Your Rights Regarding Your Data 
10. Access and Modification of Personal Data 
11. Right to Withdraw Consent 
12. Accuracy and Right to Provide Personal Data 
13. Personal Data Retention Period 
14. Transferring Personal Data outside Vietnam 
15. Contact Us 
16. Other Regulations 

 

1. Definition and Scope of Policy

1.1. This policy applies to personal data that is owned by us or under our control, and personal data that we collect, use, disclose, and/or process in Vietnam.

1.2. Unless you withdraw your consent following the procedure outlined in this Policy, we may continue to use and store the personal data that we collect from you and share it with our affiliated companies and subsidiaries. This personal data may also be stored or transferred and used outside the territory of Vietnam in accordance with the law. When personal data is collected or transferred to us, it will be processed in accordance with the personal data security standards stipulated in this Policy and comply with legal requirements for cross-border data transmission.

2. How is your data collected?

2.1. According to the law, we must obtain your consent before collecting, using, and disclosing your personal data and inform you of the purposes for doing so. When doing this, we will make every effort within our capacity to ensure that your personal data is collected accurately and comprehensively.

2.2. We collect various types of personal data. In this Policy, “personal data” means data about an individual that can be identified: (a) from that data; or (b) from that data and other information that we (and all our branches, partners, subsidiaries, and all relevant third parties mentioned in this Policy) have or may have access to. Personal data includes information that falls under the relevant legal provisions regarding information technology, network security, consumer protection, e-commerce, and other relevant legal regulations.

2.3. We collect personal data about you that you know and voluntarily provide, related to certain activities or transactions with us, including but not limited to when you submit a job application; when you register to use this website or our services; and when you report an issue with this website or our services, etc. The type of personal data we collect about you depends on the nature of the activities or transactions being conducted.

2.4. We may also collect your personal data from and disclose your personal information to our business partners (including companies with whom we may cooperate to facilitate payment processes or delivery services), branches, and independent third parties to serve the purposes as outlined in Section 3 below.

3. What types of personal data do we collect from you?

3.1. The personal data we collect from you may include:
• Name;
• Address;
• Email address;
• Username;
• Phone number (and recorded data when you call our customer service hotline);
• Credit card or other payment information;
• Age;
• Date of birth;
• Gender;
• Purchase and product usage information;
• Household information;
• Information, feedback, or content you provide related to your marketing preferences;
• User-generated content, as well as posts and other content you submit to our website;
• In limited cases, with respect to family or other individuals you have provided us with information about, we reserve the right to assume that you have obtained the full consent of the subjects of that personal information to share their personal information with us for the purposes outlined in this Policy;
• In limited cases, based on your legitimately obtained consent or to fulfill our legal obligations or if necessary for community interest reasons as stipulated by law, sensitive personal information such as information related to your image, health (including information related to product usage and medical history), sexual life (and related behaviors), and biometrics may be collected during voluntary consumer research (such as facial recognition, heart rate, and skin condition);
• Demographic information;
• Any other personal information that you voluntarily provide directly to us.

3.2. Automatically Collected Personal Data
Some personal data may be collected automatically when you access or use our website (and by third-party service providers on our behalf), such as information gathered by cookies and other technologies (such as web analytics tools and pixel tags) on our websites. Please refer to our Cookie Policy in this Policy for more information on how we use cookies and other means of automatic data collection.
The personal data collected through this method may include:
• Data about your device (mobile) or your web browser;
• Data about how you use our websites, such as the history of web pages you’ve viewed, ad patterns, and links you’ve clicked on, etc.;
• Checking whether you have opened emails we have sent to you;
• Websites you visited immediately before or after arriving at one of our websites;
• Your IP address;
• Links you’ve clicked on from websites and online fan pages;
• Your MAC address;
• Data you have chosen to share using social media tools integrated into our websites or by using your social media login details to access specific Morinaga websites or applications; and
• Data you share with us about your location. When the law permits, we will only use this data with your consent.

3.3. Personal Data Obtained from Other Sources
We may also collect personal data about you from other data sources from third parties who collect your personal data and share it with us in a lawful manner. These sources may include:
• Our trusted business partners;
• Social media platforms;
• Consumer research organizations;
• Credit reference agencies;
• Mobile data enrichment intermediaries; and
• Other companies within our Group.
The personal data collected through this method may include preferences, pets, market research and consumer data, purchasing behavior, publicly observed data, or user-generated content such as blogs, videos, internet posts, and user-generated content.

3.4. User age is mandatory information you must provide to us. If at the time of providing this information, you are under 16 years of age, you must provide us with a copy of one of the following documents: ID card, citizen’s identity card, birth certificate, or household registration book to confirm your true age. We may also request you to provide contact information for your parents or legal guardians to serve the purpose of personal data processing.

4. Why do we collect your data?

4.1. Depending on your relationship with us, the personal data we collect from you may be collected, used, and disclosed for the following purposes:
a. to verify your identity and manage the online accounts you may have set up with us;
b. to facilitate your use of services or access to this website;
c. to process orders you submit through the website (including any payments you make through the website for products, whether sold by us or any of our branches);
d. to verify and execute online financial transactions related to payments, and to identify you for anti-money laundering, suspicious transaction reporting, and fraud detection purposes;
e. to provide products you have purchased through this website, whether sold by us or a third-party seller, and to verify product delivery. We may transfer your personal data to third parties to deliver products to you (e.g., courier services or our product suppliers);
f. to carry out related activities when you participate in specific promotional programs, contests, surveys, and opinion polls as defined there;
g. to communicate with you to process and respond to your queries, feedback, complaints, or disputes, whether directly or through any outsourced customer service provider;
h. to notify you of our brands, products, and promotional programs, and invite you to upcoming Morinaga events or other marketing purposes;
i. to update you on any of our products and services as well as the latest developments at Morinaga, whether directly or through any outsourced customer service provider;
j. to send you advertising/promotional materials from any of our branches, whether directly or through any of our advertising and strategic partners;
k. to improve this website; to enhance the services and products being sold;
l. to manage or terminate employment relationships or evaluate the suitability and qualifications of potential job applicants;
m. to conduct market research on demographics, preferences, advertising, or purchasing and other user behaviors;
n. to provide you with information that we believe you may find useful or have requested from us, including information about our products and services or those of our branches, as long as you do not express opposition when being contacted for those purposes;
o. to comply with court orders or other legal processes, or legal requirements and/or other regulations of any government and/or regulatory authority; and
p. any purpose described to you at the time of collecting your data.
(collectively referred to as “Purposes“)

5. Whom do we share your data with?

5.1. We may share your personal data with third parties and our branches for one or more of the purposes mentioned above, to facilitate the use of this website or any services we provide, complete transactions with you, manage your account and our relationship with you, market and comply with any legal requirements or regulations that we deem necessary.

5.2. When sharing your personal data with external parties, we make efforts to ensure that third parties and our branches protect your personal data securely from unauthorized access, collection, use, disclosure, unlawful processing, or similar risks. They will only retain your data for as long as necessary to fulfill the Purposes outlined above.

5.3. To the extent permitted by law, all your Personal Data may be disclosed to third parties, including:
a. for our affiliated companies and brands for the Purposes described in this Policy, as we have outlined above, this Privacy Notice applies to all these companies and brands that use your Personal Information. For more information about us, our companies, our brands, and our legal presence in your jurisdiction, please visit: https://www.morinagamilk.co.jp/english/about/oversea/
b. to third parties who are our service providers, those who provide services such as website hosting, data analytics, payment processing, order fulfillment, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services, and other business operations services, to enable them to provide services;
c. To a court or competent governmental authority to comply with legal obligations related to the essential purposes described above.
d. If another company acquires (part of) our company, business, or assets, that company may obtain all or part of the Personal Information we collect and will assume the rights and obligations related to your Personal Information as described in this Policy. In the event of our insolvency or bankruptcy, your Personal Information may also be transferred as a business asset, in accordance with applicable law.

5.4. Within the limits allowed by law, your name and contact information (and other information you make publicly available) may be disclosed to third parties as follows:
a. to strategic partners with whom we have a special promotional relationship, if permitted by law;
b. to our suppliers and delivery partners if you have a business relationship with Morinaga, and sharing your information is reasonably necessary in connection with fulfilling orders or related order requests.

5.5. To the extent permitted by law, information collected passively when you use the website may be disclosed to third parties as follows:
c. online advertising service providers and email advertising service providers that we use, who are providers of cookies, pixel tags, web beacons, clear GIFs, or similar technologies used on our website or other websites to manage and enhance our online advertising campaigns and email advertising.
b. for example, providers (e.g., Google, Facebook) may provide us with specific digital advertising pixels or other tools to identify their cookies while you access the website and understand which of our online advertisements brought you to our website or to provide you with ads for Morinaga products after you leave the website. These third-party providers may also use other digital advertising tools as well as your Personal Information to recognize you across devices and online services you use. For more information about Morinaga’s use of cookies, please refer to our cookie policy as outlined below.

5.6. Morinaga will not collect, use, or disclose your National Identity Card, Citizen Identity Card number, or any other personal identification number (including Temporary Resident Card Number, Birth Certificate Number, Passport Number, and Labor Permit Number, and any other personal identification numbers specified by law) unless such collection, use, or disclosure is required by law (or falls under a legal exception); or such collection, use, or disclosure is necessary to establish or verify your identity with a high degree of integrity.

6. How do we protect your data?

We take reasonable steps to protect your personal data. We have implemented operational measures, procedures, and other measures to safeguard your personal data from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction, or accidental loss. We will apply operational measures to ensure data security, network security, and the confidentiality and protection of personal information; to prevent unauthorized access, use, alteration, unauthorized distribution of personal information, and other unauthorized actions through the following methods:
a. Implement technical infrastructure security management procedures, including (but not limited to):
• Establishing a firewall system;
• Using accounts and passwords.
b. Require all employees and relevant parties to sign strict security commitments to ensure the non-infringement of the collected personal data.

7. Direct Marketing and Product Introduction

7.1. We may periodically send you free newsletters, surveys, purchase receipts, and other advertising materials related to our products and services that we believe would be useful to you if you have agreed to receive such notifications via email or any other electronic channels that you have accessed.
7.2. If you no longer wish to receive such notifications, you will always have the opportunity to “opt-out” by following the unsubscribe instructions provided in each of our direct marketing activities in emails or by contacting us directly as stipulated in Section 14.1 of this Policy. When permitted by applicable law, we may send you specific service notifications for any updates to this Personal Data Privacy Policy of ours (even if you have opted out of receiving marketing messages from us).

8. Cookie

8.1. This website uses cookies. Cookies are small text files that can be used by websites to make the user experience more efficient. We use cookies to personalize content and advertisements, to provide social media features, and to analyze our traffic.

8.2. We may also share information about your use of this website with our social media, advertising, and analytics partners, who may combine it with other information that you have provided to them or that they have collected from your use of their services. You agree to the use of our cookies when you access our website and click “Accept”.

8.3. We can only store cookies on your device if they are strictly necessary for the functioning of this website. For all other types of cookies, we need your permission before storing them on your device.

8.4. This website uses various types of cookies. Some cookies are set by third-party services that appear on our pages. This website uses a cookie management tool called “Cookiebot” provided by Classmethod Europe.

8.5. You can change or withdraw your consent at any time through the “Change your consent” in the Cookie Declaration below.

Your consent applies to the following domains: morinagamilk .co .jp
Your current status:

Only use the necessary cookies.

Change your consent.

The cookie declaration was last updated on 12/09/2019 by Cookiebot.

Necessary (1)
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Name Provider Purpose Expiration Type
CookieConsent Cookiebot Stores the user’s cookie consent state for the current domain 1 year Cookie HTTP


Analytics (4)
Analytics cookies help website owners understand how visitors interact with the website by collecting and reporting anonymous information.

Name Provider Purpose

Expiration

Type
_ga mnf-ap.com Register a unique ID used to generate statistical data on how visitors use the website. 02 years Cookie HTTP
_gat mnf-ap.com Used by Google Analytics to adjust the request rate. 01 day Cookie HTTP
_gid mnf-ap.com

Register a unique ID used to generate statistical data on how visitors use the website.

01 day Cookie HTTP
Collect Google Send data to Google Analytics about the device and behavior of the visitor. Tracks the visitor across devices and marketing channels Period Pixel Tracker

 

9. Your Rights Regarding Your Data

Your rights regarding your Personal Data that we collect, store, and process include:
a. Access to view and request a copy of the Personal Data we store about you.
b. Requesting us to limit the use of your Personal Data.
c. Requesting us to update your Personal Data or correct any Personal Data that you believe is inaccurate or incomplete.
d. Requesting us to delete the Personal Data we store about you.
e. Withdrawing your consent at any time in the future regarding our processing of your Personal Data (to the extent that such processing is based on your consent).
f. Objecting to our processing of your Personal Data, including for direct marketing purposes.
g. Complaining with the relevant state authority responsible for data protection if you are dissatisfied with how we process your Personal Data or if you have any queries or requests regarding your privacy rights that you have shared with us.

10. Access and Modification of Personal Data

10.1. You can request access to your personal data that we have collected, stored, or inquire about how your personal data may have been used, disclosed, stored, or processed in the past year. You can also request to rectify any errors or omissions in your personal data profile at any time.

10.2. To facilitate the processing of your access or correction requests, we may need to request additional information related to your request.

10.3. If you wish to access, correct, or supplement any errors or omissions in your personal data profile, please contact us as outlined in Section 13.1 below. We will respond to your request as soon as possible. If we cannot fulfill your request within thirty (30) days from the date of your request, we will notify you in writing. If we are unable to provide you with any personal data or make the requested amendments, we will inform you of the reasons for our inability to do so (unless we are not required by current data protection laws to do so).

10.4. Right to Restrict Processing of Personal Data: The company must fulfill requests to restrict the processing of personal data within 72 hours of receiving the data subject’s request.

10.5. Right to Object to the Processing of Personal Data: The company must fulfill data subject requests within 72 hours of receiving the request.

10.6. Right to Lodge a Complaint.

11. Right to Withdraw Consent

11.1 You may withdraw your consent to continue using, disclosing, storing, and/or processing your personal data for any of the purposes mentioned above at any time by contacting us as specified in Section 13.1 below.
11.2 Please note that if you withdraw your consent to us using, disclosing, storing, or processing your personal data for the purposes mentioned above, we may not be able to continue providing services to you or fulfill any contractual terms with you, and we will not be held responsible in the event we cease to provide services or fulfill our contracts with you. In such cases, our legal rights and remedies will still be reserved.
11.3 We will respond to your request as soon as possible to confirm your withdrawal of consent. If we cannot respond to your request within seven (7) days from the date of your request, we will notify you in writing. If we cannot confirm that your consent has been withdrawn, we will explain the reasons why we cannot do so (unless other applicable data protection laws stipulate otherwise).

12. Right to Withdraw Consent

12.1. You are responsible for ensuring the accuracy and completeness of the personal data you provide to us. You may inform us of any changes to your personal data or if you believe that the personal data we have about you is inaccurate, incomplete, misleading, or outdated.

12.2. You can update your personal data at any time by contacting us as indicated in Section 13.1 below.

12.3. If you provide the personal data of any third party to us, you represent and warrant that you have obtained the necessary consent, licenses, and permissions from that third party to share and transfer their personal data to us and for us to collect, store, use, and disclose that data in accordance with this Policy. You must provide us with legal documentation proving that you have obtained the required consent and permission.

12.4. We may take steps to share updated personal data with third parties and our affiliates with whom we have shared your personal data if your personal data remains necessary for the stated Purposes.

13. Personal Data Retention Period

13.1. We may retain your personal data for as long as the Purposes for which the personal data was collected continue to be valid, or if the retention is necessary for our business or legal purposes, even in cases where you have closed your account with us. The retention period may exceed the duration of your relationship with us.

13.2. We will cease to retain personal data when we no longer have any reason to continue holding such data. Your personal information will be deleted or securely disposed of following our established system procedures and in compliance with applicable laws.

14. Transferring Personal Data outside Vietnam

14.1. By providing us with your personal data, you understand and agree that your personal data may be transferred to servers located in Vietnam. Additionally, to ensure that you are aware of the storage and processing location when your personal data is transferred outside the territory of Vietnam, including transferring data to other branches, we will inform you and seek your consent regarding this matter.

14.2. In the event we transfer your personal data abroad, we will take steps to ensure appropriate and necessary levels of protection are maintained to preserve the security and integrity of your personal data. We will ensure that the receiving party can provide protection standards equivalent to the protection standards as per the law for the transferred personal data.

15. Contact Us

If you have any questions about this Policy or any other inquiries related to how we manage, protect, and/or process your personal data, please contact us using the phone number and email address provided below:
Telephone number: +84-208-3866-472
Email Address: info@elovi.com.vn
Our Address: Nam Pho Yen Industrial Park, Thuan Thanh Commune, Pho Yen Town, Thai Nguyen Province, Vietnam.

16. Other Regulations

16.1. This website may contain links to other websites operated by third parties, such as our business branches, vendors, or payment gateways. We are not responsible for the data protection practices of websites operated by third parties. You should review the current data protection policies of those websites to understand how they will process any information they collect from you.

16.2. This policy will be updated and amended over time to ensure compliance with new regulations in Vietnam. Any content not specified in this policy will be executed according to Vietnamese law.

16.3. This policy is effective from August 2023.

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