Privacy Policy

For external individual

(Effective from July 1, 2023)

1. General terms

This Privacy Policy, or the Personal Data Processing Notice (“Notice”), applies to Customers of Nin Sing Logistics Company Limited (“Ninja Van”) and any individual whose Personal Data is processed by Ninja Van (collectively referred to as “User”), by using Ninja Van's services or providing information to Ninja Van via other communication channels (“Services”). In this Notice, the term “we” refers to Ninja Van or third parties authorized by Ninja Van, and the term “you” or “your” refers to Users.

Ninja Van always respects your privacy and seriously implements regulations on Personal Data protection following Vietnamese law, this Notice, contracts, and other commitments (if any) between you and Ninja Van.

By registering an account, registering for a trial, choosing to use our Services, or providing your Personal Data via the platforms mentioned below, and/or any other consent forms which can express consent in a format that can be printed, reproduced in writing, you agree and consent to allow Ninja Van to process your data by the terms and conditions set out in this Notice.

Where the Customer provides Personal Data of a third party to Ninja Van (such as name, address, and phone number of the consignees), through your use of the Services, the Customer represents and warrants that the Customer has obtained the consent of such third party for Ninja Van’s processing of Personal Data (including but not limited to collection, use, and transfer), and information that Ninja Van is the party processing Personal Data for the purposes set out in this Notice and/or in the contract or commitment (if any) between the Customer and Ninja Van.

This Notice provides information in detail about the Users’ Personal Data we shall process, the purpose of processing Personal Data, how we process your data, your rights and obligations as a data subject, undesirable consequences and damages, and other related content.

This Notice may be amended and supplemented by us from time to time depending on changes in our operations and/or as required by law. Updates to the Notice will be posted on our official website and other platforms (if any) at our discretion. We recommend that you check this page carefully and regularly to keep up to date with changes related to the processing of Personal Data as set out in this Notice.

2. Types of Personal Data and how it is collected

“Personal Data” refers to electronic information in the form of symbols, letters, numbers, images, sounds, or equivalences associated with an individual or used to identify an individual. Personal Data includes General Personal Data and Sensitive Personal Data.

Depending on the purposes, Ninja Van may collect Users’ General Personal Data and Sensitive Personal Data, including:

Last name, middle name and birth name
Date of birth
Sex
Permanent residence address
Current residence address
Home town
Contact Address
Nationality
Phone number
Identity card number
Personal identification number
Information about individuals' digital accounts and Personal Data reflecting activities in cyberspace, specifically:
- Information on purchase orders, including product description, quantity, payment information, and consignees’ information (name, phone number, delivery address);
- IP address, types of browsers, unique device identifiers, activities records, website usage history, Cookies, and location:
- Personal information and data on third-party platforms, provided that Ninja Van has permission from Users to integrate with the Ninja Van application (API) in accordance with that third party's Open Platform Developer programme.
Bank account;
Other information related to Ninja Van's service provision.

We may collect Personal Data of Users where Users register for an account, log in with a linked account from a third party, and perform any interactive actions on Ninja Van’s application or integrated platforms, where Users contact Ninja Van for any inquiries about the Services, or in the course of Ninja Van providing Users with any of Ninja Van's products and services, or from other variety of sources, including but not limited to:

You, your representative or other authorized persons;
Person or company who uses Ninja Van’s delivery service;
Business partner and/or agent of Ninja Van;
Via Ninja Van’s services through various channels such as stations, applications, telephone service (Call Center), and e-mail;
Through files created by the website that the User visits (cookies) or similar tools;
From third-party sources where the User consents to the sharing or provision of Personal Data, or where the collection is required or permitted by law;
When Users use Ninja Van's websites, applications or social networking sites, Ninja Van will collect Personal Data declared or made public by the User; and
Any reliable sources such as governmental entities.

3. Processing of Personal Data

3.1 Purposes

Processing of Personal Data refers to one or multiple activities that impact Personal Data, including collection, recording, analysis, confirmation, storage, rectification, disclosure, combination, access, traceability, retrieval, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction or other relevant activities.

We may process your data for one, some or all of the purposes listed below:

Manage administrative and business activities of Ninja Van and comply with internal policies and procedures;
Exalt the performance of delivery services;
Track Users’ delivery route;
Notify Users of order status or delivery;
Contact the Users to receive feedback later or during delivery;
Respond and handle Users queries and requests;
Conduct investigations related to disputes, payments or frauds;
Resolving complaints, problems or disputes;
Facilitate communication between riders and Users;
Monitor or record phone calls and interact with Users to ensure quality, staff training and performance reviews;
Provide notification and communication feedback;
Conduct research and analysis to enable us to better understand positions, interests, demographics and to improve service delivery and Users experience at the respective points of contact;
Handle all claims and insurance payments that may arise under Ninja Van's policies;
Legal purposes (including but not limited to obtaining legal advice and dispute resolution);
Accounting, risk management, compliance and record keeping;
Satisfy or comply with any applicable rules, laws, regulations, practice rules or guidelines issued by any legal authority or regulation binding to Ninja Van; and
The purpose is reasonably related to the foregoing;
To facilitate Users to use the Service (as defined in the Terms of Use);
To process orders you submit through Ninja Van system, whether the products are sold by Ninja Van or a third party seller. Payments that you make through Ninja Van system for products, whether sold by Ninja Van or a third party seller, will be processed by our payment service provider;
To deliver the products you have placed through Ninja Van system, whether sold by Ninja Van or a third party seller. We may transfer Users information to third parties for delivery of products to Users (e.g. our courier or supplier);
To compare information and verify with third parties to ensure that the information is accurate;
Moreover, we will use the information provided by Users to manage the account (if any) with us; verify and perform financial transactions related to Customers-made payments online; audit data downloads from the system; improve the layout and / or content of the web pages, applications and customize them for Users; identify visitors on the system; conduct research on demographics and behavior of our uUsers; provide Users with information that we think Users may find useful or Users have requested from us, including information about our third party or products and services, as long as the Users indicates that the Users does not object to contacting these purposes;
When a User registers an account with Ninja Van or occasionally provides us with personal information through the system, we will also use the Users' personal information to send marketing emails and/or advertise our products and services. Users can unsubscribe from marketing information at any time by using the unsubscribe function in the email. We may use Users' contact information to send newsletters from us and our related companies; and
In exceptional circumstances Ninja Van may be required to disclose personal information, such as when there are grounds to believe that the disclosure is necessary to prevent a threat to life or health, for law enforcement purposes, or for the fulfillment of legal and regulatory requirements and requests (such as Ninja Van is responsible for co-operating in providing Users’ personal information as and when requested by the tax authority, customs authority or juridical authority).

3.2 Transfer and Disclosure of Personal Data

Ninja Van does not provide, transfer, or disclose to any third party the User's data without the User's consent, except where permitted or required by law or to the following subjects to carry out the purposes and data processing activities set out in this Notice:

Ninja Van's parent company, subsidiaries, affiliated companies and employees;
Agents, contractors or service providers for Ninja Van to whom the transfer or disclosure of data is necessary for Ninja Van to perform its obligations to Users;
The parties have the User's consent to provide the User's data;
Ninja Van's auditors, consultants, and lawyers;
Insurance Company;
Competent state agencies;
Any people or companies where required in connection with potential or actual corporate restructuring, merger, acquisition or takeover, including any transfer or potential transfer of Ninja Van’s rights or duties under the agreement with a data subject

Where Ninja Van discloses and transfers the Personal Data of a data subject to a third party above (apart from competent state agencies and bodies), Ninja Van will take the necessary steps to ensure that the third party will handle the Personal Data of a data subject in accordance with applicable regulations so as to prevent data loss, unauthorised access, improper use, modification, disclosure, or processing of Personal Data. Where Personal Data is transferred aboard, Ninja Van commits to complying with applicable Personal Data regulations on Personal Data transfer abroad.

3.3 Processing Time of Personal Data

Starting time

We will begin processing your Personal Data since Ninja Van receives the Personal Data.

End time

We will stop processing the User's Personal Data after the completion of processing data in line with the stated purposes or where the User submits a valid and lawful request to delete, limit or object Personal Data processing there is a request to delete, restrict, or object to Personal Data processing.

3.4 Personal Data Retention

Your data stored by Ninja Van will be kept confidential. To the extent permitted by law, your data may be stored on servers in Vietnam or using foreign services (including cloud storage solutions). Regardless of storage form, Ninja Van applies strict security standards to the extent possible, by current legal regulations to protect your Personal Data (see also Section 4 of this Notice).

Your Personal Data may be retained until such data is no longer necessary for the purposes detailed in this Notice and for any operational or legal purposes unless you withdraw your consent and submit a valid and lawful request to Ninja Van to delete your Personal Data.

4. Personal Data Protection

We commit to protecting your Personal Data by applying technical measures and internal regulations in accordance with applicable regulations so as to prevent data loss, unauthorised access, improper use, modification, disclosure, or processing of Personal Data. These measures may include:

Promulgate and apply internal policies and regulations to manage and protect Personal Data under our control;
- On the application layer:
  - Data Storage Encryption to secure data at the storage layer, i.e. application data stored in the cloud;
  - Application communications are secured via HTTPS and/or TLS to secure data in-transit when the user is communicating with Ninja Van application like OpV2;
  - Data masking on the application interface to protect sensitive data on Ninja Van applications like OpV2.
- On the Identity Access Management layer:
  - Role-based access control (RBAC) which is the rule of least privilege, to only grant users the access they need to perform its function and limit the number of privileged accounts or “super admins” to the applications;
  - Download controls where users cannot download information if they are not authorized to;
  - Multi-factor authentication (MFA) by requiring users to identify themselves by using more than just a password and username;
  - Single sign on (SSO) enables the Company to have more granular control over user accounts.
- On the collaboration platform layer, we have PII (Personal Identifiable Information) discovery and alerts. It is an automated scanning for both G Drive and Emails for files that contain PII and subsequently raises an alert to the InfoSec team if it matches any of the predefined conditions.
- On the endpoint layer:
  - Endpoint encryption to protect drive and attachments;
  - Web Data Loss Prevention (DLP) monitors file transfer via the Internet as well as transfers to the cloud;
  - Endpoint DLP to actively scan and have granular device control.

5. Users' rights and obligations regarding Personal Data

Regarding your Personal Data, you have the following rights: (i) Right to know; (ii) Right to consent; (iii) Right of access; (iv) Right to withdraw consent; (v) Right to request data deletion; (vi) Right to restrict data processing; (vii) Right to provide data; (viii) Right to object to data processing; (ix) Right to complain, denounce and sue; (x) Right to claim compensation for damages; (xi) Right to self-defence and other related rights as prescribed by law.

Users may exercise their rights by contacting Ninja Van using the details provided in section 6 of this Notice, Ninja Van will comply with your lawful and valid request within the time specified by law from the date of receipt of that request.

5.1 For requests to access, provide and correct Personal Data

Users can check, update and adjust their Personal Data by logging into their account and editing personal information or asking Ninja Van to do this by contacting us according to the information in section 6 of this Notice.

5.2 For the right to withdraw consent, erase data, restrict processing and object to processing of Personal Data

You may exercise these rights in respect of any or all Personal Data you provide/allow us to collect. However, we note that complying with these requests, depending on the scope of the specific request, may result in our provision of the Services to you being limited, suspended, or cancelled. Therefore, depending on the scope of the User's requests, we may consider these requests as a unilateral decision to terminate the User's Contract. In any such event, we will not be liable for any User’s losses and damages arising from such termination.

Your requests set out in this section do not affect the lawfulness of the processing of Personal Data previously consented to by you.

5.3 Ensure the accuracy of Personal Data

Ninja Van relies on Personal Data provided by Users to provide Services to Users. Therefore, Users need to ensure that at all times, the information provided by Users to Ninja Van is true, accurate and complete. Users need to promptly update all changes to the information provided to Ninja Van.

5.4 User's obligations in Personal Data protection activities

Protect your Personal Data; request other relevant organizations and individuals to protect their Personal Data;
Respect and protect the Personal Data of others;
Provide complete and accurate Personal Data when agreeing to process Personal Data;
Participate in propagating and disseminating Personal Data protection skills;
Implement legal regulations on Personal Data protection and participate in preventing and combating violations of Personal Data protection regulations;
In case Users provide Personal Data of other individuals to us, Users must ensure that they have received the consent or valid authorization of these individuals before providing their Personal Data to us.

6. Undesirable consequences and damages

We pledge to secure your personal information by taking all appropriate and required measures. But because of its nature, the Internet cannot be considered a safe place, so we cannot guarantee that all of your personal information will be completely protected in the following cases: (i) a cyberattack on Ninja Van's system and network results in a data leak; (ii) hardware and software vulnerabilities arise during the data processing process; (iii) you use public and other unsecured networks and devices to store and transmit your personal information; and (iv) any secure matter pertaining to other third parties' network outside Ninja Van websites.

In the event that Ninja Van becomes aware of any unauthorised access, cyberattack, or other violations impacting your Personal Data, we will notify you immediately and take the required steps to minimise any damage that occurs.

In addition, Ninja Van advises you to safeguard your ID account and password on any website you use to transfer Personal Data, avoid using unlicensed software or unsecured networks when accessing the Internet, and take other proactive steps to manage and protect your Personal Data.

7. Contact

Should you have any questions regarding this Notice or requests, concerns, or complaints about Ninja Van's processing of your Personal Data, you can contact us at the following information:

NIN SING LOGISTICS COMPANY LIMITED

Head office: 117/2D1 Ho Van Long Street, Tan Tao Ward, Binh Tan District, Ho Chi Minh City

Hotline: 1900 886 877

Email to Data Protection Officer: vn-privacy@ninjavan.co