HELP

PERSONAL INFORMATION PROTECTION POLICY

This Policy is effective as of November 1, 2025.

1. INTRODUCTION

1.1. ALPHA SPACEZ JOINT STOCK COMPANY and affiliates of ALPHA SPACEZ JOINT STOCK COMPANY (individually referred to as “ALPHA SPACEZ” or collectively as “We”) greatly respect your privacy – the user on the website ZZP.VN (“Website”). In Vietnam, the legal entity controlling your personal data is ALPHA SPACEZ JOINT STOCK COMPANY (English name: ALPHA SPACEZ JOINT STOCK) – the owner of the Website.

1.2. In the course of providing you with Services or access to the Website (as defined in the Terms of Use), We will collect, use, disclose, store, and/or process data, including your personal data.

1.3. This Personal Information Protection Policy (“Policy”) is established to help you understand how we collect, use, disclose, store, and/or process data that We collect and receive during your access and performance of operations and transactions on the Website. We will only collect, use, disclose, store, and/or process your personal data in accordance with this Policy.

1.4. You need to read this Policy together with any other applicable notices that We may provide in specific cases when We collect, use, disclose, and/or process personal data about you, ensuring you are fully aware of how and why We use your personal data.

1.5. We may update this Policy from time to time. Any changes We make to this Policy in the future will be reflected on the Website, and significant changes will be notified to you. Your continued use and transaction on the Website, or explicit consent thereto, will constitute your acknowledgment and acceptance of the changes We make to this Policy. You agree that you are responsible for checking back regularly for any updates or changes to this Policy.

1.6. This Policy applies in conjunction with other notices, contractual clauses, and consent clauses that apply in relation to the collection, storage, use, disclosure, and/or processing of your personal data by Us and is not intended to override those notices, contractual clauses, and consent clauses unless We state otherwise expressly.

1.7. All these terms apply to all users on the Website.

2. PERSONAL DATA WE COLLECT FROM YOU

2.1. Personal data means any information about an individual, whether recorded in material form or not and whether true or not, that can identify the individual from that data (whether directly or indirectly), or from that data combined with other data We have or can access.

2.2. During your use of the Website, We may collect your personal data as follows:

(i) Identity data, such as name, gender, personal image, and date of birth;

(ii) Contact data, such as billing address, delivery address, email address, and telephone number;

(iii) Biometric data, such as voice recording files when you use our voice search function, and facial features and other body features and voice of yourself and/or others in your videos when you upload videos;

(iv) Account data, such as bank account details, account statements, credit card information, and payment information (these account data may be collected directly by affiliates and/or third-party payment service providers;

(v) Transaction data, such as information about orders and payments, and other information of products and services related to you;

(vi) Technical data, such as Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and Website, international mobile equipment identity, device identifier, IMEI, MAC address, cookies (if applicable) and other information and technology on the devices you use to access the Website;

(vii) Profile data, such as your username and password, orders related to you, interests, preferences, feedback, and survey responses;

(viii) Usage data, such as information about how you use the Website, view product information and services or view any content on the Website, including the time spent on the Website, items and data searched for on the Website, access times and dates, as well as websites you visited before accessing the Website and other similar statistics;

(ix) Location data, such as when you capture and share your location with Us in the form of photos or videos and upload such content to the Website;

(x) Marketing and communications data, such as your preferences in receiving marketing and advertising from Us and our third parties and your communication preferences and your chat, email, and call history on the Website or with third-party customer service providers; and

(xi) Additional information We may request you to provide for identity verification purposes (such as copies of government-issued identification documents like passports, ID cards) or if We believe you are violating our Policy or Terms of Use.

2.3. During your use of the Website, We may receive your personal data in the following situations:

(a) When you visit our website (both mobile and desktop versions or similar electronic devices);

(b) When you create an account with Us (as a Customer);

(d) When you perform a transaction related to the services We provide on the Website;

(e) When you activate or use payment-related functions available on the Website or provided by a third-party service provider;

(f) When you record any user-generated content and upload it to the Website;

(g) When you use the chat function on the Website;

(h) When you subscribe to our publications or marketing support tools;

(i) When you participate in a contest, promotion, or survey;

(j) When you participate in any activity or campaign on the Website;

(k) When you log in to your account on the Website or interact with Us via an external service or application, such as Facebook or Google linked to the Website;

(l) When any other user on the Website posts any comment on the content you have uploaded to the Website or when you post any comment on other users' content uploaded to the Website;

(m) When a third party lodges a complaint against you or the content you have posted on the Website; and

(n) When you interact with Us directly, including when you interact with our outsourced customer service agents (if any).

2.4. We may collect personal data from you, third parties (including but not limited to agents, vendors, contractors, partners, and any other person who provides services to Us, who collect your personal information and/or perform functions on our behalf, or with whom We collaborate, including but not limited to payment service providers, government data sources, financial service providers, credit bureaus, delivery, marketing, and other service partners), our affiliates, or such data may be collected automatically when you use the Website, as set out in this section. See also section 11.3 below regarding computer data collection.

2.5. Where We collect personal data through third parties and/or our affiliates, We will only collect your personal data where permitted by law or in connection with the purposes for which those third parties and/or our affiliates have engaged, for the purposes of our collaboration with those third parties and/or affiliates, or for verification or identity checks. By using the Website, you acknowledge that you have consented (whether to Us, the third party, or our affiliates) to the transfer of your personal data from third parties and/or our affiliates for the purposes set out in this Policy or any other terms.

2.6. You must submit personal data that is accurate and not misleading and you must keep it up to date and inform Us of any changes to the personal data you have provided to Us. We shall have the right to request documentation and carry out the necessary checks to verify the personal data provided by you as part of our user verification processes or as required by law.

2.7. We will only be able to collect certain categories of personal data if you voluntarily provide the personal data to Us or as otherwise provided for under this Policy. If you choose not to provide your personal data to Us or subsequently withdraw your consent to our use of your personal data, We may not be able to provide you with certain features or functionality on the Website.

2.8. If you provide personal data of any third party to Us, you represent and warrant that you have obtained the necessary consent, license, and permission 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.

2.9. If you sign up to be a user on our Website using your social media account or link your Website account to your social media account, We may access personal data about you which you have voluntarily provided to your social media provider in accordance with such provider's policies, and We will manage your personal data in accordance with this Policy.

3. PURPOSE OF PERSONAL INFORMATION COLLECTION

3.1. The personal data We collect (as set out in section 2 above) from you or via third parties may be used by Us for the following purposes:

(i) Processing Your Orders

To process service requests you make via the Website;
We may pass your information to a third party (e.g., our service providers, payment affiliates on the Website) or competent authority to provide services to you;
To update you on the status of service provision;
To provide customer support for your Orders; and
To verify and carry out payment transactions (including any credit card payments, bank transfers, cash payments, remittances, or e-wallet transactions) in relation to payments related to you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers.

(ii) Providing Services Requested by You on the Website

To facilitate your use of the services or access to the Website;
To administer your account (if any) on the Website;
To display your name, username, or profile on the Website (including views you make);
To support the use of mini-apps available on the Website (if any);
To respond to your queries, feedback, claims, or disputes, whether directly or through our third-party service providers;
To display on scoreboards on the Website in relation to campaigns, mobile games, or any other activity (if any);
To assess your application for loans and/or to assess credit risk for applications for financial services (where applicable); and
To support the integration of third-party loyalty programs with our Website.

(iii) Marketing and Advertising

To provide you with information We think you may find useful or which you have requested from Us (provided you have opted to receive that information);
To send you marketing or promotional information about our products and services on the Website from time to time (provided you have opted to receive that information);
To help Us conduct marketing and advertising; and
To promote the services and use information that you provide to Us, such as user-generated content (including video content) that you choose to upload or broadcast on our Website and which will be accessible on the Internet and may be shared by the public (over which access and sharing We have no control), as part of our advertising and marketing campaigns to promote the Website.

(iv) Legal and Operational Purposes

To identify you in connection with fraud detection;
Comparing information, and verifying with third parties to ensure that the information is accurate;
To process any complaints, feedback, enforcement actions, and take-down requests in relation to any content you have uploaded to the Website;
To produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
Storing, hosting, backing up your personal data;
To prevent or investigate any actual or suspected violations of our Terms of Use, Policy, fraud, unlawful activity, omission, or misconduct, whether relating to your use of our Website or any other matter arising from your relationship with Us;
To perform due diligence checks;
To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details, and company details), including any law enforcement requests in connection with any legal proceedings or as We deem necessary; and
Where necessary to prevent a threat to life, health, or safety.

(v) Analytics, Research, Business and Development

To understand your user experience with our services and the Website;
To improve the layout or content of the pages of the Website and customize them for users;
To identify visitors on the Website;
Conducting surveys, including carrying out research on our users' demographics and behavior;
To improve our current technology (e.g., voice recognition technology, etc.) via machine learning or other means;
To derive further attributes relating to you based on personal data provided by you (whether to Us or third parties), in order to provide you with more targeted and/or relevant information;
To conduct data analysis, testing, and research, monitoring and analyzing usage and activity trends;
To develop and upgrade our products and services; and
To understand Customers better.

(vi) Other Matters

Any other purpose to which you have consented; and
To conduct automated decision-making processes in accordance with any of the above purposes.

4. SCOPE OF INFORMATION USE AND METHOD OF COLLECTION, CONTROL, AND PROCESSING OF YOUR PERSONAL INFORMATION

4.1. The personal data We collect will be used domestically or transferred abroad to serve the purposes set out in this Policy.

4.2. Your personal data will be collected, controlled, and/or processed by Us through the Website, mobile application, information on contracts, or relevant documents. In addition, We may receive your personal data from affiliates, partners, other service providers when you consent to provide personal information to Us, or from public administrative agencies and government organizations.

4.3. We commit that the collection, storage, and processing of your personal information via Google Workspace APIs will not be for the purpose of developing, improving, or training generalized AI and/or ML models.

5. INFORMATION RETENTION PERIOD

5.1. We will only retain your personal data where permitted by law or relevant to the purposes for which the data was collected.

5.2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data was collected and is no longer necessary for any legal or business purpose.

5.3. Without prejudice to other terms and conditions provided herein, your personal data will be stored until you request deletion of your personal data and/or deactivation of your user account on the Website.

6. PERSONS OR ORGANIZATIONS WHO MAY BE GIVEN ACCESS TO INFORMATION

6.1. In Vietnam, the legal entity controlling your personal data is ALPHA SPACEZ JOINT STOCK COMPANY (English name: ALPHA SPACEZ JOINT STOCK) – the owner of the Website.

6.2. We may share (or permit the sharing of) your personal data and/or transfer your personal data to third parties and/or our affiliates for the purposes mentioned in this Policy. These third parties and affiliates may be located inside or outside Vietnam, including but not limited to:

(i) Service providers and their related companies (e.g., agents, contractors, and partners in areas such as payment services, logistics and delivery, marketing, data analytics or customer survey research, social media, customer service, installation services, information technology, and web hosting services).

6.3. In disclosing your personal data to third parties, We ensure that such third parties and our affiliates will keep your personal data secure from unauthorized access, collection, use, disclosure, processing, or similar risks and retain your personal data only for such period as is necessary to achieve the above-mentioned purposes.

6.4. We may also share personal data in connection with any purchase, merger, or acquisition of our business, provided that We satisfy the requirements of applicable data protection law when disclosing your personal data.

6.5. We may transfer or permit the transfer of your personal data outside of Vietnam for any of the purposes set out in this Policy. However, We will not transfer or permit any of your personal data to be transferred outside of Vietnam unless the transfer is in compliance with applicable law.

6.6. We may share your personal data with third-party service providers or our affiliates (e.g., payment service providers) for them to offer services to you other than those you use on the Website. Your acceptance and use of the third-party service provider's or our affiliate's services shall be subject to terms and conditions agreed between you and the third-party service provider or our affiliate. Upon your acceptance of the third-party service provider's or our affiliate's service offering, the collection, use, disclosure, storage, transfer, and processing of your personal data (including your personal data and any data disclosed by Us to such third-party service provider or affiliate) shall be subject to the applicable privacy policy of the third-party service provider or our affiliate, who shall be the data controller of such data. You agree that any queries or complaints relating to your acceptance or use of the third-party service provider's or our affiliate's services shall be directed to the third-party service provider or affiliate named in the applicable privacy policy.

7. ADDRESS OF THE INFORMATION COLLECTION AND MANAGEMENT UNIT

If you have any queries or complaints about this Policy or how We handle your personal data, please contact Us via our live chat function integrated on the Website or via the following contact details:

ALPHA SPACEZ JOINT STOCK COMPANY

Address: 210 Bui Van Ba, Tan Thuan Ward, Ho Chi Minh City, Vietnam

Telephone: +84 816 869 993

Email: support@zzp.vn

8. METHODS AND TOOLS FOR CONSUMERS TO ACCESS AND EDIT THEIR PERSONAL DATA ON THE E-COMMERCE SYSTEM OF THE INFORMATION COLLECTION UNIT

8.1. In order for you to continue using the Website and for Us to provide the services, the personal data you provide to Us must be accurate and complete. You are responsible for informing Us of changes to your personal data, or in the event you believe that the personal data We have collected about you is inaccurate, incomplete, misleading, or out of date.

8.2. You can update your personal data at any time by accessing your account on the Website.

8.3. We take steps to share the updates to your personal data with third parties and our affiliates if your personal data is still necessary for the above-stated purposes.

8.4. You may request information about your personal data which We have collected or inquire about the ways in which your personal data may have been used, disclosed, stored, or processed by Us by contacting Us. You may also request the correction of any error or omission in your personal data which We have collected in the same way. In order to facilitate the processing of your request, We may need to request further information from you. Where permitted by law, We may refuse such correction requests if they are vexatious or unreasonable.

8.5. Where permitted by applicable data protection laws, We reserve the right to charge a reasonable administrative fee for retrieving your personal data records. If so, We will inform you of the fee before processing your request.

9. COMMITMENT TO PERSONAL INFORMATION SECURITY

9.1. To safeguard your personal data from unauthorized access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse, modification without your permission, or similar risks, we have introduced appropriate administrative, physical, and technical measures such as:

(a) Limiting access to personal data to individuals who require access;

(b) Maintaining technology products to prevent unauthorized computer access;

(d) Implementing other security measures as required by applicable law.

9.2. However, you should be aware that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, We strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

9.3. The Website may contain links to other websites operated by other parties, such as our business affiliates or payment gateways. We are not responsible for the privacy practices of websites operated by these parties. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you.

10. MECHANISM FOR RECEIVING AND RESOLVING CONSUMER COMPLAINTS

10.1. If you suspect that your personal data has been misused or used beyond the scope We have notified, you may lodge a query or complaint about how We use your personal data via our live chat function integrated on the Website or via the contact details set out in section 7.

10.2. Our data protection officer will receive your complaints and depending on the nature and severity of your query or complaint, We will take specific measures to resolve your query or complaint.

11. OTHER PROVISIONS

11.1. Withdrawal of Consent to Continued Use, Disclosure, Storage, and/or Processing of Personal Data

(a) You may communicate the withdrawal of your consent to the continued use, disclosure, storage, and/or processing of your personal data by contacting Us using the contact details in section 7, subject to conditions and/or limitations imposed by applicable laws or regulations.

(b) Please note that if you communicate your withdrawal of your consent to our use, disclosure, storage, or processing of your personal data for the purposes and in the manner as stated above or exercise your other rights as available under applicable laws, We may not be in a position to continue to provide the services to you or perform any contract We have with you, and We will not be liable in the event that We do not continue to provide you with access to the Website or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.

(c) You may unsubscribe from receiving marketing information at any time in our mobile application settings or by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from Us and from our related companies.

11.2. Minors

(a) We do not sell products or provide services to minors (as determined by applicable law), nor do We intend to provide access to the Website to minors. We do not knowingly collect any personal data relating to minors.

(b) You hereby confirm and warrant that you are above the age of majority and you are capable of understanding and accepting the terms of this Policy. If you are a minor, you may use our Website only with the involvement of a parent or legal guardian.

(c) As a parent or legal guardian, please do not allow such minors under your care to submit personal data to Us. In the event that such personal data of a minor is disclosed to Us, you hereby consent to the processing of the minor’s personal data and accept and agree to be bound by this Policy and take responsibility for his or her actions.

(d) We will not be responsible for any unauthorized use of the services on the Website by yourself, users who act on your behalf, or any unauthorized users. It is your responsibility to make your own informed decisions about the use of the services on the Website and take necessary steps to prevent any misuse of the services on the Website.

11.3. Collection of Computer Data

(a) We or our authorized service providers may use cookies, web beacons, and other similar technologies in connection with your use of the services or access to the Website.

(b) When you visit the Website through your computer, mobile device, or any other device with Internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website, such as the technical data and usage data set out in Section 2.2 above.

(c) This data is collected for analysis and evaluation in order to help Us improve our website/apps and the services and products We provide, as well as to help Us to personalize content to match your preferred interests more quickly. The data is also collected to make the services and the Website more convenient and useful to you, and to provide more relevant advertising related to market products, services, and features to you.

(d) Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow Us to recognize a particular device or browser. Web beacons are small graphic images that may be included on our services and the Website. They allow Us to count users who have viewed these pages so that We can better understand your preference and interests.

(e) You may be able to manage and delete cookies through your browser or device settings. However, certain cookies are required to enable core functionality (such as adding items to your shopping basket), so please note that changing and deleting cookies may affect the functionality available on the Website.

ZZP is developed by Alpha SpaceZ Joint Stock Company