PRIVACY POLICY

HONDA VIETNAM COMPANY LIMITED

Last updated and applied on and from 1^st July 2024

By consenting to this Privacy Policy ("Policy"), you agree to allow HVN to use your personal data for the purposes and means set forth herein. In case you do not agree or have any other comments regarding the purposes of processing personal data or other detailed information about the Policy, please inform HVN via the methods provided under the Contact Us section.

Honda Vietnam respects and protects your privacy

Honda Vietnam Company Limited ("HVN" or "we") is committed to protecting and respecting your privacy. This Privacy Policy provides you with information about how HVN treats your personal data including but not limited to when: (i) you go to a distributor; you access, use and provide information through HVN's websites; you download and use HVN’s applications or other sensor devices; you contact us or use goods or services provided by HVN or participate in programs or events organized by us (such as contests, games, promotions, events, fairs and exhibitions organized or participated by us, from your interactions with us (e.g., through social media, answering survey questions, registering for events and/or receiving prizes, etc.), (collectively, "Interactions"), and (ii) we collect your personal data from other third parties. This Policy also outlines your rights regarding your personal data. More details about your rights can be found in the following section Your Choices and Rights.

We may also provide you with additional information during our collection of your personal data, and when we deem the provision of such information is appropriate and helpful.

Data that we collect and process

Personal data is information that pertains to a particular person or helps to identify a particular person ("Personal Data"). Based on the source of collection, the Personal Data we collect may include, but is not limited to, the following information:

Basic personal data:

• Contact information or personally identifiable information: such as full name, date of birth, gender, height, weight, occupation (including title, place of work), education level, user employer, nationality, marital status, permanent residence, temporary residence, current residence, hometown, contact address, photo of the individual, phone, emergency contact information, email, passport, national identification (or other personal identification numbers including, but not limited to, issuance date, place of issue and issuing authority), social media accounts, and driver's licenses
• Personal data reflects activities or activity history in the cyberspace
• Information to create a user profile, such as username, password, PIN or security questions and answers;
• Vehicle information: such as Vehicle Identification Number (VIN), trademark, model, year of manufacture, colour, place of purchase and date of vehicle purchase, vehicle performance, license plate number, condition information your driving conditions and behaviour, vehicle condition (engine, temperature, fuel consumption, battery voltage, etc.), trip log, mileage and driving activity remote vehicle control, vehicle registration;
• Other product information: such as product ID and date and place of purchase;
• Cookie, Web Beacon and similar technologies: We may receive and store certain information about your usage patterns or browsing behavior through cookies, web beacons and similar technologies. These technologies may be provided by third parties. Cookies are small text files that are stored on your computer or other devices that connect or access the Internet to help websites and applications recognize your browser. Cookies help us provide you with customized services and can be used to deliver personalized advertising or to connect you to social networking sites. We may use both session cookies (which disappear after you close your browser) and persistent cookies (which remain after you close your browser and help remember a user's information, settings, preferences, or sign-on credentials that the user has previously saved) when you are connected to HVN's website(s). You may change your cookie settings as needed. However, some features on our website(s) may not work properly if you disable cookies. Web beacons are transparent graphic pixels placed on a webpage that enables a third party or us to track your activity on our websites and deliver advertisements accordingly based on your personal preference. We will provide additional information about online tracking and interest-based advertising, including opt-out options later in this policy;
• Social Media: Our websites and mobile applications include social networking features connected to social networking platforms such as Facebook, Twitter, Instagram, Snapchat, Google Plus, Pinterest, YouTube and other platforms. These features may collect information about your IP address and the pages you visit on our website, and these platforms may create cookies or use other tracking technologies. Social media features and facilities may be set up by a third party or set up directly on our website. Your interactions with those features will be governed by the privacy policies of the companies providing these features;
• Any other Personal Data that you enter or decide to provide to us when you Interact with HVN including but not limited to family status, interests, behaviours, questions, complaints, comments, signatures, photos, videos and your location.

Sensitive personal data:

• Information related to racial and ethnic origin
• Information about inherited or acquired genetic characteristics of an individual
• Financial Information, such as your bank account number, account name, bank name and billing address, income, vehicle financing, etc.;
• Payment Information: Credit card, payment method (Cash/Transfer/Installment), payer  and other payment information;
• Location Information: We receive location information from the devices you use to connect to HVN's website(s) and/or when accessing HVN apps. Location information may be obtained through the use of geolocation features in your devices or sensors, or through other methods such as using your IP address to define your general geographic area;

Collection of Personal Data

We may collect and process any Personal Data during your Interactions with us. You must ensure that the data you provide is complete, accurate, and up-to-date in order to ensure the protection of your rights per the regulation of the relevant use of services. We are not responsible in the event that you provide inaccurate, out-of-date, or incomplete data.

If you provide us with the Personal Data of a third party, you represent and warrant that you have obtained the valid consent of that third party prior to your provision of their Personal Data to HVN in accordance with this Privacy Policy.

You also warrant and undertake that the information you provide to HVN does not contain any of the following types of information: (i) state secrets, (ii) business secrets; and (iii) any other information that you are not authorized to provide by law or a confidentiality agreement.

We may collect your Personal Data from other entities, including but not limited to service providers (such as rescue, insurance, installments, credit, etc.), partners, referral programs, publicly available sources; and/or when another user provides your Personal Data to us with your authorization and/or consent via documents, surveys, investigations, promotions, etc. When we collect your Personal Data from other entities, we ensure that such Personal Data is transferred in accordance with applicable laws.

Automated Data-Collection

We also collect information and data that is not associated with nor identifiable to one particular individual. We may collect, use, transfer, and disclose information that is not Personal Data for any purposes.

For example, we may collect information from the devices (computers, tablets, smartphones, etc.) that you use to connect to the HVN website(s) or you use to host or access HVN applications. The information we receive from these devices may include the device's serial number, other identifiers, MAC address, browser type, Internet service provider, hardware information, operating system, connection information, and app information. When you use and/or interact with HVN's website(s) or applications, we may also collect and record certain information and store that information in log files. This information may include source and last visited pages, timestamps and dates, search terms and sequence data.

If we aggregate non-Personal Data with your Personal Data, such aggregated information will be classified and treated as Personal Data.

Means and Purpose for the Processing of Personal Data

We may directly process or authorize or hire other parties to process your Personal Data by automated or non-automated means, to the extent and for the purposes mentioned in this Policy.

On Which Legal Bases That We Collect, Use, Store, Share, and Process Personal Data

1. Your consent ("Consent");
2. The need to perform a contract with you ("Contract");
3. The goal of protecting your life or health or that of others in an emergency ("Life & Health Protection");
4. The use of your personal image from public activities without damaging your honor, dignity, or reputation ("Public Use");
5. Obligation to comply with the provisions of the law ("Legal Obligations").

We may collect, use, store, share, and process your Personal Data for the purposes and on the legal bases as set out below:

1. To provide HVN websites or HVN applications and related products and services to you, including but not limited to the following:
   • To evaluate and improve our services, for example to develop new products or services, and to improve and manage existing infrastructure systems;
   • To create, administer and update user accounts, and verify user identity;
   • To manage, operate, provide and/or administer your use and activity when you Interact with us;
   • To access information stored on your device to understand your preferences and improve your customer experience, for example, by providing you with customized content and tailored offers to your personal preferences;
   • To perform any contract that HVN or other related parties have with you (for example, to facilitate online payments and provide products and services);
   • To allow us to understand your interests and preferences so that HVN websites or HVN applications can be tailored to your needs;
   • To respond to your requests, such as sending you promotional materials, locating the nearest HVN distributor, scheduling a ride for you, or arranging a service for you related to vehicles or products of HVN; assist you in purchasing a vehicle or using services provided by HVN or its distributors; support you to participate in or receive rewards and prizes at promotions, events, programs, contests organized by HVN or its distributors;
   • To notify HVN distributors and affiliates of any upcoming service, test-driving schedule or other appointment relating to you or your HVN vehicle or product; and
   • To respond to questions and complaints from users.

Legal basis: Contract Performance, Consent.

2. To support, maintain and improve HVN websites, applications, and related products and services, including but not limited to the following:
   • To manage HVN's website or HVN's applications;
   • To improve and optimize HVN's websites or HVN's applications and HVN's products and services;
   • To investigate and address technical issues;
   • To monitor and improve feedback from HVN customer support;
   • To receive, respond, and resolve customer support issues;
   • To request users’ opinions or survey participation (which may be conducted by us or a third party) about our vehicles, products, services, and distributors; and
   • To monitor usage, analyze performance, find ways to improve and develop websites, applications, products, and services.

Legal basis: Consent.

3. For research and development purposes, including but not limited to:
   • Conduct research, analysis, testing and development activities including but not limited to data analysis, surveys, product and service development and/or customer profiling, to analyze how you conduct activities on HVN's platforms, improve products and services to enhance the user experience, develop new features, products and services, and facilitate solutions finance and insurance while protecting data, improving and enhancing safety, security, and privacy.

Legal basis: Consent.

4. To contact you for the aforementioned purposes (directly by HVN or through a company within the Honda Group, or an authorized HVN distributor or a related partner or distributor) by courier, phone, e-mail, message, or automated notification.

Legal basis: Contract Performance, Consent.

5. For internal storage, management, backup for incident recovery or other similar purposes.

Legal Basis: Contract Performance, Legal Obligation.

6. HVN may also convert Personal Data into anonymous data or receive data from third parties in an unidentified form on the basis of a legal contract and use such data (generally on an approved basis), for example to research and analyze the market, to improve HVN's products and services, to analyze trends and evaluate the success of advertising campaigns.

Data analytics techniques are used to study your online activity and ownership history of products and services so that you have a more seamless experience when interacting with HVN online and offline.

Information that has been anonymized will not be considered as Personal Data for the purposes of this Privacy Policy.

7. For marketing and advertising purposes, including but not limited to:
   • Advertising/marketing information, product or service recommendations, commercial and other information, or offers, proposals, offers related to Honda products and services that may be of interest to you by post, telephone, instant messaging, e-mail, social media (e.g. Facebook), online forums, blogs, announcements automated and other methods or platforms (e.g. electronic methods, online methods).
   • Where you accept the processing of Personal Data for advertising/marketing purposes, you will always have the opportunity to withdraw your consent and unsubscribe from our newsletters.

Legal basis: Consent.

8. To fulfill legal obligations, including but not limited to:

We have a legal obligation to collect, use or store your Personal Data under certain circumstances, including but not limited to: When requested, advised, recommended or otherwise demanded inquired by legal counsel or by any legal regulation, by-law, document or request of any local or foreign government or authority; When performing statutory obligations, including disclosure obligations, promotional reporting, record keeping, auditing, investigation, complaint or dispute resolution, and other services; Comply with court orders or legal requirements; Enforce other terms, conditions or agreements; And protect our rights or property in the event of a claim or dispute.

Legal Basis: Legal Obligation, Consent.

9. To prevent and investigate fraud, unlawful conduct, evasion of duty or misconduct that may or may not be caused by or in connection with the provision of Honda services.

Legal Basis: Legal Obligation, Consent.

10. To protect our customers, employees, and other individuals, and protect the data, secrets and property of and entrusted to Honda and our affiliates, and protect the safety of systems and facilities of Honda and our affiliates.

Legal Basis: Life & Health Protection, Legal Obligation, Contract Performance, Consent.

11. When necessary to protect the legitimate interests and legal rights of HVN, including but not limited to:

Using information for compliance, regulatory, audit, and litigation reasons (including disclosure in connection with relevant legal or litigation procedures) and other ethical and/or compliance reporting requirements.

Legal Basis: Legal Obligation, Consent.

Without contravening any applicable laws, we may collect, use, store, and process your Personal Data for other purposes as we deem necessary or appropriate.

How We Share Your Personal Data

We may share your personal data for the following parties with any or all of the purposes as set forth in section Means and Purpose for the Processing of Personal Data above.

1. Provision of Personal Data between Companies within the Honda Group

We may share customer Personal Data with members of the Honda group. For this purpose, your Personal Data may be transferred to, processed in, or accessed from a country outside Vietnam (e.g., Japan).

2. Provision of Personal Data to HVN distributors and authorized repairers

We may share your Personal Data with HVN distributors and authorized repair parties in Vietnam. For example, if you make an online request to schedule a vehicle test-drive or other product-related service, we will ask your local HVN distributor to contact you to arrange a road test or provide the service at an appropriate time.

3. Provision of Personal Data to contract service providers

We may provide your Personal Data to HVN's suppliers, consultants, marketing partners, research firms and other service providers or business partners, including but not limited to: term: payment processing partners and support; anti-money laundering services; server service provider, information technology service provider, cloud computing service provider; advertising partners and advertising platform providers; data analytics provider; research partners, including those conducting surveys or research projects in partnership with HVN or on behalf of HVN; insurance and financial partners. Your Personal Data may also be shared with third parties who are advisors, specialists, dealers or service providers, subcontractors of companies within the Honda Group.

4. Provision of Personal Data to other organizations or parties

We may provide your Personal Data to other user(s) and owner(s) (whether present or future) of your Honda-branded vehicle (including cars and motorcycle) warranty information, service history and other information (if any) relating to such Honda-branded vehicle if we deem this necessary to facilitate the use of Honda-branded vehicles and/or Honda applications.

We may provide your Personal Data to third parties as required by existing legal obligations or if we consider the disclosure necessary for us to protect the rights, property, and safety of HVN, our customers and others. The foregoing may include exchanging information with other companies and organizations to prevent and detect fraud, and to mitigate risk.

We may provide your Personal Data to relevant government agencies and/or law enforcement or as necessary to protect our legitimate interests in compliance with applicable laws.

We may provide your Personal Data to potential or actual buyers in the event that HVN, or any part of the Honda group, sells any business or asset including your personal data. We may also retain a copy of this information after the sale.

We may provide your Personal Data to relevant parties in the event of bankruptcy, merger, acquisition, or restructuring involving HVN, and your Personal Data/information may be sold or transferred as part of that transaction. We may also retain a copy of this information.

Your Rights and Choices and Obligations

1. Your Rights as a Data Subject

In addition to the right to consent, to be informed about the processing of Personal Data, and to exercise the rights of self-protection in accordance with civil law, you have the right to exercise these rights by logging into your account or by submitting a request by contacting HVN via the contact information provided in section Contact Us.

• View, correct or request correction of your Personal Data;
• Withdraw your consent to the processing of your Personal Data (in case Personal Data is processed on the basis of consent);
• Restrict the processing of your Personal Data;
• Provide your Personal Data to yourself;
• Object to the processing of Personal Data in order to prevent or limit the disclosure of your Personal Data or its use for advertising or marketing purposes; and
• Delete Personal Data.

These rights may be limited, for example, if fulfillment of your request would reveal Personal Data about another person, or if you ask us to destroy information we are required to retain as required by applicable laws or in situations where we have a legitimate interest to withhold, or when such acts are restricted by law.

2. Your Obligations

In addition to the aforementioned rights, you, as a data subject, also have obligations under the law, such as respecting and protecting the Personal Data of others and providing complete and accurate information.

HVN will not be responsible for your violations of applicable laws on the protection of Personal Data and this Policy. You agree to indemnify and hold HVN harmless and not liable for any and all of your non-compliance with applicable laws on the protection of Personal Data and with This Policy (including but not limited to not impersonating another individual when providing Personal Data to us, and only providing another person's Personal Data to us with the consent of data subject).

3. Give a review and share your thoughts

When using our websites or mobile applications, you may share information via social networks such as Facebook and Twitter. For example, you can 'like', 'share' or rate our services. In doing this, your Personal Data may be disclosed to the providers of such social networks and/or their other users. HVN is not responsible for your privacy when you use your social media accounts. You are responsible for selecting appropriate safety settings on your social media accounts to manage how your information is used and shared on these social networks.

Advertising and Marketing

We will ask for your consent to use your Personal Data for advertising and marketing purposes. If you do not want us to send you advertising/marketing information, or use your Personal Data to profile you in connection with advertising/marketing purposes, or send your Personal Data to third parties for advertising/marketing purposes, you can ask us not to, at any time, by:

• Responding to a promotional/marketing e-mail by pressing the 'unsubscribe' key;
• By changing privacy settings in an app (if available on the app);
• By contacting us;
• By following the opt-out or unsubscribe instructions set forth in our relevant communications;
• By following the relevantinstructions provided by us from time to time.

Data Retention and Protection, Retention Period

1. Data Retention and Protection

We will implement sufficient measures to protect your Personal Data. We have measures to reasonably protect your Personal Data that we collect from a technical and physical perspective. However, please note that although we will take reasonable steps to protect your Personal Data, no website, transmission over the Internet, computer system, or wireless connection or any safeguard is 100% secure and we cannot guarantee that your Personal Data is entirely safe. For example, we cannot ensure protection against the unauthorized access and use of Personal Data by hackers.

Some of our safety measures include: (a) we restrict access to your Personal Data on a "need to know" basis and only for the purpose for which it has been advised; (b) we monitor access to our information technology systems to detect and prevent misuse of Personal Data; (c) we use technological controls over our information systems, such as firewalls, user verification, data encryption, and roles, systems & data.

If you have a personal password that allows you to access certain parts of our websites or any other portal, application or service that we operate/manage, please do not forget your responsibility to maintain the confidentiality of the password. We ask that you do not share your password with anyone else.

2. Retention Time

We will only retain your Personal Data for as long as we need it to fulfill the Personal Data processing purposes set out in this Policy, unless Vietnamese laws provide otherwise. At the end of the retention period or as we see fit, we may, at our discretion and in accordance with the law, take steps to destroy your Personal Data, or store such Personal Data in the anonymized form, unless Vietnamese laws provide otherwise.

Links to third-party websites or applications

Our website or applications may, from time to time, contain links to or from the websites of our network of partners, advertising agencies, and other companies within the Honda group. HVN is not responsible for the content provided by any website linked to HVN's website or applications. When accessing a third-party website or downloading a third-party application, it is your responsibility to ensure that you have read the respective privacy policy as well as the terms and conditions applicable to such website or application.

Update this Policy

This Policy may be updated from time to time. Accordingly, we will update the date at the beginning of this Policy and encourage you to check for changes to this Policy as published on HVN's website. In some cases, we may also proactively notify you of specific data processing activities or material changes to this Policy and obtain your consent to such changes, if applicable laws so require.

Contact Us

If you have any questions or concerns regarding this Policy, please contact us at:

Honda Vietnam Company Limited

Head office: Phuc Thang, Phuc Yen, Vinh Phuc, Vietnam.

Email: cr@honda.com.vn

Hotline: 1800 8001

Honda Vietnam Company Ltd

    Koji Sugita

            General Director