Privacy Policy

1. Introduction

The Privacy Policy (hereinafter referred to as "Policy") clarifies how CONVERSION ASIA LIMITED LIABILITY COMPANY (hereinafter referred to as "Conversion Asia", "Company" or "we", "us", "our") processes and protects personal data collected in connection to the usage of the app [SocialOne] (hereinafter referred to as the "App") and its related services.

This Policy is intended to provide detailed information regarding the categories of personal data processed by the Company, the purposes for which such data is processed, the methods and procedures involved in the processing, the entities or individuals with whom such data is shared or processed, and to inform you of your rights and obligations as a data subject.

This Policy applies to users of all versions of the App (hereinafter collectively referred to as "user(s)" or "you", "your", "yours"), regardless of the platform. This Policy supersedes all prior notices or terms concerning the processing of personal data that may have been communicated to you. To the extent permitted by applicable laws, your consent to this Policy shall constitute valid consent and serve as the legal basis for the Company's processing of your personal data.

The Company may issue additional personal data processing notices as required by specific circumstances. These additional notices will generally provide further details relating to, but not limited to, supplementary purposes for processing your personal data that are not explicitly addressed in this Policy. Such notices will apply exclusively to the specific instance referenced and will not affect the validity or enforceability of this Policy.

For the purposes of this Policy, "personal data" refers to information in the form of symbols, letters, numbers, images, sounds, or equivalents in the electronic environment associated with an individual or used to identify an individual.

2. Consent

Unless otherwise permitted by the applicable laws or regulations, we will notify you and obtain your consent for our processing of your personal data by methods or means such as signing a form or checking a box via physical or electronic means.

By giving consent, you represent that:

• Your consent, once given, is valid;
• You have read, understood and agree to your rights and obligations under this Policy; and
• Where you provide information about another individual, (i) such individual has been notified of this Policy and other necessary information regarding the processing; and (ii) you are able to and do give valid consent on behalf of such person, or provide us with a valid legal basis for processing the personal data of such individual pursuant to this Policy.

Regarding the processing of personal data of children, we always respect and protect their personal data and abide by the applicable laws.

3. Categories of Personal Data Collected

We may collect personal data that is reasonably necessary for the relevant processing purposes listed under this Policy. Examples of such personal data may include:

3.1 User Account Information

Users' account information on the App: User name, email, avatar or profile image, user profile ID, etc.

3.2 Social Media Data

Users' interactions and account information on social media platforms and browsers (such as but not limited to Facebook, Instagram, X, Reddit, etc.), which may include: user names, IDs, avatar or profile image, reactions, shares, public comments, live stream view counts, contents interacted with, duration of interaction, etc.

3.3 Delivery Information

Information required for delivery of physical items, such as your name, mailing address, phone number, etc.

4. Personal Data Collection Methods

The Company collects personal data through various lawful methods. Examples of such methods include:

• When you sign up to use the App via our website(s), mobile application(s), online portal(s), or any other registration channels/methods;
• Through lawful data collection mechanisms (e.g. Application Programming Interfaces – APIs) provided by social media platforms (Facebook, Instagram, X, Reddit, etc.) and browsers, in compliance with each platform's respective terms of use and policies;
• Through automated tools such as web crawlers developed by us;
• Through cookies or other online-tracking methods when you visit our websites or use our technologies;
• From publicly available and legal sources;
• When you actively provide us with personal data for any reason and via any format (e.g. via installation of browser extension, account creation);
• From third parties via legal transfer mechanisms.

5. Personal Data Processing Purposes

Conversion Asia processes your personal data mainly to manage your relationship with us, provide the services to you and our clients/business partners, facilitate the operation of the App, perform activities of the Company, and comply with applicable laws. The specific purposes for processing, collectively referred to as "Purposes", are outlined below:

5.1 Managing and Operating the App and Related Services

Which may include activities such as:

• To register, verify, reissue, lock, or cancel Accounts;
• To manage Account usage activities;
• To communicate and provide information about rewards programs, gifts, promotions, memberships, appreciation events, etc.;
• To offer you new products or services (if any) at specific times, including fee-based activities, payments, returns, warranties, recalls, retrievals, or replacements for those goods or services;
• To implement point accumulation, rewards redemption, addressing inquiries, requests, questions, complaints, and providing customer support related to the App and the provided goods or services;
• To deliver prizes under the applicable rewards Programs to you;
• To upgrade, update software, patches, release new features, and enhance user experience;
• To establish and maintain security measures for the App;
• To investigate and review violations or fraudulent activities.

5.2 Providing Services to Clients and Partners

Which may include activities such as:

• To provide data to our clients to facilitate the verification of users' social media interactions and implementation of the rewards programs as detailed in the Terms of Use;
• To monitor and analyze the development of communities relating to the brands of our clients and partners on social media;
• To analyze and create reports regarding the market and the products and services of our clients and partners.

5.3 Managing the Activities of the Company

Which may include activities such as:

• To seek professional advice, including legal advice, or enforce your obligations and our rights, including, without limitation, the collection of amounts owed by you or by any other person, or defending our rights and benefits and/or any of our related entities, partners, contractors or third-party service providers;
• To handle complaints, denunciations, disputes and violations; conduct investigations or take action in relation to crime and fraud prevention, detection or prosecution, risk management, violation of terms and conditions for services provided by us or prevent any individual from harm, illegal or unlawful activities;
• To perform and comply with internal/external audits or for other compliance purposes;
• To comply with regulatory, compliance, or legal obligations and/or requirements; and
• For any other purposes (i) permitted or required by the applicable laws, industry codes or market rules, (ii) necessary, ancillary or consequential to the above-specified purposes, or (iii) desirable or necessary for the performance of services under the Terms of Use.

6. Personal Data Disclosure

In accordance with the Purposes outlined in this Policy, during operation, the Company may disclose, share, transfer, provide access to, or otherwise make available (hereinafter collectively referred to as "share") users' personal data to relevant parties (hereinafter referred to as "Recipients of Personal Data"). For clarity, Recipients of Personal Data are authorized to process such data in compliance with the Purposes specified in this Policy.

Recipients of Personal Data may include:

• Entities that provide services supporting the Company's operations, such as information technology, telecommunications, cloud computing and data storage, analytics, investigation services, legal advisory, survey and statistical services, background checks, among others;
• Our respective business partners, clients relevant to the services being rendered to the users (e.g., point reward program, community management platform, other products under SocialOne platform);
• Government agencies, regulatory bodies, law enforcement authorities, or other public institutions as required by applicable law;
• Any future successor/owner of the App;
• Any other party to whom you authorize/consent us to disclose personal data.

7. Personal Data Processing Methods

To the extent permitted by applicable laws, the Company may process personal data by a variety of methods, which may include manual, mechanical, or automated means. These methods may be employed individually or in combination to achieve the Purposes. The Company may process personal data directly or through our personal data processors in accordance with applicable laws. When engaging personal data processors, the Company shall ensure the establishment of legally binding agreements and the selection of processors that implement appropriate technical and organizational measures to safeguard the confidentiality and security of personal data.

8. Personal Data Processing Locations

In addition to being processed within Vietnam, your personal data may be transferred to various international locations to fulfill any of the Purposes specified in this Policy.

In the event of transferring your personal data beyond the territory of Vietnam, the Company shall ensure full compliance with applicable legal requirements and implement robust safeguards prior to the transfer. These measures may include, but are not limited to, conducting data transfer impact assessments, executing legally binding data transfer agreements or contracts with the recipients, and implementing appropriate organizational and technical measures to ensure the security and confidentiality of your personal data.

9. Personal Data Processing Time

We begin processing personal data upon receiving your consent (where consent is the legal basis for processing) or from the moment personal data is collected (where we rely on other legal basis for processing).

The Company shall retain personal data strictly for the duration necessary to achieve the Purposes for which it was collected and processed, such as managing our relationship with the users, providing the services to the users, operating the App, or pursuing or defending legal claims.

Once the Company no longer has a lawful basis to retain personal data, or upon expiration of the retention period mandated by applicable laws or requested by regulatory bodies, the Company will delete or destroy the personal data in a secure manner.

10. Your Rights and Obligations as Data Subjects

10.1 Rights of Users as Data Subjects

Unless otherwise provided by law, as a data subject, you have the following rights with respect to your personal data:

Right to consent, withdraw consent, restrict, and object to processing

You have the right to consent, partially consent, conditionally consent, or refuse to allow the Company to process your personal data for specific Purposes. You may withdraw your previously provided consent, request restrictions on processing, or object to the processing of your personal data.

Right to access and rectify personal data

You have the right to access, correct, and request the correction of your personal data being processed by the Company. The Company will take reasonable measures to fulfill your request and ensure that the processed data is accurate, complete, and up-to-date.

Right to request the provision of personal data

You may request, in writing, the provision of your personal data processed by the Company, either to yourself or to another individual or organization (attached with the recipient's written consent). You may also request personal data of other individuals be provided to you (attached with their written consent).

Right to request deletion of personal data

Unless otherwise restricted by applicable law, we will delete your personal data upon receiving a valid request in the following circumstances: (i) You no longer find the data necessary for its originally agreed-upon Purposes, and you accept any resulting consequences; (ii) You withdraw your consent; (iii) You object to the processing, and we lack legitimate grounds to continue; (iv) The data was processed inconsistently with its agreed-upon Purposes or in violation of applicable law; or (v) Applicable law mandates the deletion of the data.

Right to file complaints, denunciations, or take legal actions and seek compensation

You have the right to file complaints, denunciations, initiate legal actions, and seek compensation for damages if the Company violates personal data protection regulations, except as otherwise agreed or provided by applicable law.

10.2 Methods of Exercising Your Rights

To exercise your rights, you may submit a request via the official communication channels specified in this Policy. Upon receiving a request, the Company will take necessary measures to verify your identity or that of your authorized representative and the validity of the request. Additional information may be required to facilitate this verification process.

10.3 Obligations of Users as Data Subjects

• Provide accurate and complete personal data as required by law and the Company, and promptly update or correct it in the event of changes or inaccuracies. You shall assume full responsibility for the accuracy, completeness, and legality of your personal data and any personal data of other data subjects that you provide, whether directly or indirectly, to us;
• Safeguard your personal data and respect and protect the personal data of others;
• Ensure that the Company has a lawful basis to process any personal data of other individuals that you provide to the Company, as outlined in this Policy;
• Promptly report any signs, incidents, or breaches related to personal data to the Company;
• Comply with the terms, conditions, and provisions outlined in this Policy and any other documents relating to personal data of the Company from time to time;
• Comply with applicable laws and regulations concerning personal data.

11. Personal Data Protection Measures

Conversion Asia is committed to implementing and maintaining robust organizational and technical measures to ensure the protection of your personal data. These measures adhere to recognized best practices and include, but are not limited to:

• Establishing comprehensive policies and procedures for the processing and safeguarding of personal data;
• Defining roles and responsibilities related to personal data protection and conducting impact assessments for personal data processing activities;
• Granting access to personal data exclusively to authorized personnel performing relevant duties and enforcing physical access controls to restricted areas of the Company premises;
• Utilizing specific data protection techniques, including encryption, pseudonymization, and anonymization, when appropriate and necessary;
• Selecting personal data processors with adequate data protection measures, and requiring personal data processors engaged by the Company to adhere to appropriate security measures in accordance with industry standards and written instructions to ensure the confidentiality and security of your personal data.

12. Policy Update

The Company may revise this Policy from time to time and will publish the latest version publicly. When necessary, the Company may notify you of changes to this Policy via one or various platforms (e.g., websites, the App) upon your first access after the Policy is updated, or via other channels as designated from time to time (e.g. an email to your registered email address).

The updated Policy will take effect on the date specified in the notification, unless otherwise specified.

13. Contact Information

Should you have any inquiries or concerns regarding the processing of your personal data under this Policy, you may contact us through: