PRIVACY POLICY OF VINMEC INTERNATIONAL GENERAL JOINT STOCK COMPANY
I. General Principles
- This Privacy Policy describes how Vinmec International General Joint Stock Company (“Vinmec”) collects, receives, compiles, stores, uses, processes, discloses, shares and keeps confidential the Customer Information of relevant organizations and individuals (“Customer” or “you”), including cusstomers, agents, suppliers, contractors and partners who: (i) use services provided directly at medical facilities of Vinmec or other services provided by Vinmec and Vingroup; (ii) access and use customer interaction channels owned by Vinmec, including but not limited to www.vinmec.com website, My Vinmec application, other websites and groups on social network (such as Facebook, etc.) (“Vinmec Channel”) (“together, “Services”).
- “Customer Information” means any information, data that can be used to identify the Customer or upon which the Customer is identified, such as name, nationality, telephone number, payment card and bank details, personal preferences, email address, location, photo, ID card/citizen identity card, date of birth, marital status, insurance information, transactional information, access history, customer journey, health/medical records, biometric data.
- Privacy Policy. Vinmec will post the amended, supplemented and/or updated Privacy Policy on www.vinmec.com website. The Customer’s continued use, access to any Vinmec Channel, continued use of the Services constitutes the Customer’s consent to the content of that amended, supplemented, and/or updated Privacy Policy.
- Privacy Policy is made bilingual in Vietnamese and English, in the event of any discrepancy between Vietnamese version and English version, the Vietnamese version shall prevail.
- Privacy Policy includes the following contents:
5.1. Customer Information We Collect
II. Customer Information We Collect
III. How We Secure Customer Information
- At Vinmec, security is our highest priority. We design our systems with your security and privacy in mind. All Customer Information is stored and kept confidential by Vinmec’s system or service provider for Vinmec in accordance with the law and this Vinmec Privacy Policy.
- When collecting data, Vinmec will exert its best endeavours to the permitted extent to store and secure Customer Information at a server system and these information is secured by firewalls, access control measure and data encryption. We employ appropriate technical and security measures to prevent as much as possible to the permitted extent unauthorized access and use of Customer Information. Vinmec also regularly cooperates with security experts to be updated with the latest information on network security to ensure the safety of Customer Information.
- The information of your payment card issued by the relevant financial institution is protected by us in accordance with international standards on the principle that no important data of the payment card (card numbers, full names, CVV number or other verification numbers with the same legal) is recorded in our system. Your payment transaction is made by the relevant bank system.
- The Customer may not use any tools, programs or methods to illegally interfere with the system or alter the data structure of any Services, nor carry out any other activities to spread, promote activities with purpose of intervening, sabotaging or infiltrating Vinmec system’s data, as well as activities violating Vietnamese laws. In case we detect a violation, we reserve the right to transfer information about the violation to the competent authorities in accordance with the laws.
- You are responsible for protecting your account information and shall not provide any information related to your account, password or authentication methods (eg., OTP) accessed on websites, applications, software, and other tools (if any).
- We store Customer Information to ensure that you are able to use the Services continuously, and store it for as long as necessary to fulfill the Purpose, or as otherwise required by law (including for tax and accounting purposes), or to perform other work as notified to you in advance. The period we store specific Customer Information varies depending on the Purpose or as required by laws. When the Customer Information is no longer needed for the provision of the Services or Purpose or Vinmec no longer has a business or legal purpose to retain Customer Information, we will take steps to prevent the access to or use of Customer Information for any purpose other than to comply with this Privacy Policy, or for the security, confidentiality, fraud detection and prevention purposes; or removing identifiable information of Customer Information in accordance with applicable laws.
- Customer Information may be stored in, accessed from or transmitted to many countries, including Vietnam. When we transfer your Customer Information to other countries, we will ensure that such information is transferred in accordance with this Privacy Policy and is permitted under the relevant laws and regulations.
IV. How We Use Personal Information
We use your personal information to operate, provide, and improve Services for the purposes (“Purposes”) include:
7. Purposes for Which We Seek Your Consent: We may also ask for your consent to use your Customer Information for a specific purpose that we communicate to you.
V. How We Share Customer Information
Information about our customers is an important part of our operation and we are not in the business of selling our customers’ Customer Information to others. We share Customer Information only as described below and as permitted by law. All of the third parties who receive Customer Information in accordance with this Privacy Policy are subject to this Privacy Policy, other similar policies and other relevant laws.
- Complying at the request of the competent state authority, or as required by laws;
- Transactions Involving Third Parties: We make available to you services, software, and content provided by third parties for use on or through Services. You can tell when a third party is involved in your transactions, and we share information related to those transactions with that third party.
- Third-Party Service Providers: We employ and/or cooperate with other companies and individuals to perform certain functions on our behalf. Examples include: sending communications, processing payments, assessing credit and compliance risks, analyzing data, providing marketing and sales assistance (including advertising and event management), conducting customer relationship management, and providing training. These third party service providers have access to Customer Information needed to perform their functions, but may not use it for other purposes. Further, they must adhere to this Privacy Policy and the applicable data protection law.
- Restructuring, Business Transfers: As we continue to develop our business, we might restructure, sell or buy businesses or services in accordance with the laws. In such transactions, Customer Information, database and right to use information generally are amongst the transferred business assets but the transferee remains subject to the Privacy Policy (or the individual consents otherwise). Also, in the event that Vinmec or substantially all of its assets are acquired, your information will be one of the transferred assets.
- Protection of Us and Others: We release account and other Customer Information when we believe release is appropriate to comply with the law, enforce or apply our terms and other agreements, or protect the rights, property, or security of us, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.
- At Your Option: Other than as set out above, you will receive notice when Customer Information about you might be shared with third parties, and your choice on sharing the information.
- Sharing Without Your Consent: As per prevailing laws, your Customer Information as part of your medical information, subject to permission by the head of the medical examination and treatment facility, might be shared among practitioners of a group directly providing treatment to patients for quality improvement of diagnosis, care and treatment of patients; or to certain persons including apprentices, researchers, practitioners in the medical facility who are allowed to borrow the medical records for reading on site or copying for research or technical and professional matters; or as required by Vietnamese competent authorities.
VI. Access and Choice
- Unless otherwise provided by laws, you can view, update, and delete certain information about your account and your interactions with Services. If you cannot access or update your information yourself, you can always contact us for assistance.
- You have choices about the collection and use of your Customer Information. Many of Services include settings that provide you with options as to how your information is being used. You can choose not to provide certain information, but then you might not be able to take advantage of some of Services.
a) Account Information: If you want to add, update, or delete information related to your account, please follow Vinmec’s instructions from time to time. When you update or delete any information, we usually keep a copy of the prior version for our records for technical purpose.
d) Browser and Devices: The Help feature on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
VII. Contacts, Notices, and Revisions
Our business changes constantly, and our Privacy Policy may also change. You should check our website frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all Customer Information we have about you and your account. If you have any concern about privacy at Vinmec or want to contact one of our data controllers, please contact us and we will try to resolve it. You may also contact us at the address below: info@vinmec.com.
VIII. Additional Information for the EU
APPENDIX 1 – CUSTOMER INFORMATION TO BE COLLECTED IN THE COURSE OF USE OF MYVINMEC APPLICATION
(attached to the Privacy Policy of Vinmec International General Hospital Joint Stock Company)
When Customer use MyVinmec application, we collect Customer Information including the following information and other information to be collected as per this Privacy Policy:
- Information you give us: when Customer creates and administers your account, we will ask you to provideinformation including: the name, age, email address, date of birth, permanent and contact address, phone number and other similar contact information; usernames, aliases, roles, and other authentication and security credential information; information relating identity, including government-issued identification information, nationality;..
- Informationabout the visits, vaccination history, examination and test results (including Covid-19 test results) which are supplied by Vinmec facilities. This information will be used by us to suggest services that Customer may be interested in, identify your preferences and personalize your experience with MyVinmec application (“Application”).
- Information we receive from Customer use of our Application, including:
Information about Application usage behavior: the content Customer viewed or searched for, page response times, and page interaction information (such as scrolling, clicks) to perform internal operations necessary to provide services, including troubleshooting software failures and operational issues, optimize the experience during use, conducting data analysis, testing and diagnosis;