Home Pixel Privacy Policy

Effective date: 01 March, 2025

SECTION 1: INTRODUCTION

The website https://homepixel.net and the Home Pixel platform ("Home Pixel") are developed, owned, and operated by FPT AdTrue Joint Stock Company ("Company" or "AdTrue").

This Terms of Use Agreement outlines the principles and conditions for user activities on Home Pixel, ensuring compliance with applicable laws. It defines your rights and obligations as well as those of Home Pixel, aiming to create a safe, engaging, and legally compliant environment. This policy complies with the Law on Network Information Security 2015, Decree No. 13/2023/ND-CP on Personal Data Protection, and other relevant regulations in Vietnam.

The terms in this Agreement are publicly available on the website https://homepixel.net and the Home Pixel investment platform. They constitute a binding agreement between you, the Company, and other users regarding all activities on Home Pixel.

Before using Home Pixel, you must confirm that you have read, understood, and agreed to all terms. By clicking "Agree," you enter into a legally binding contract with the Company under these terms. You also acknowledge that this Agreement may be updated or modified at any time by the Company without prior consultation with users, to comply with current laws and internal Company regulations. Changes will take effect immediately upon your continued use of Home Pixel.

If any disputes or violations arise from your failure to comply with these terms, you will be fully responsible before the Company, any third parties, or the law.

SECTION 2: PERSONAL DATA PROTECTION POLICY

  1. User Rights Regarding Personal Data Protection

1.1 Users are informed about the processing of their personal data (including automated processing) as described in these Terms of Use and/or through notifications from Home Pixel, which the User acknowledges by reading, understanding, and consenting to proceed with the data processing.

1.2 Users have the right to access their account to view, edit, or request corrections to their personal data.

1.3 Users can withdraw their consent for data processing, request limitations on data processing, object to processing, or request that the Company provide their personal data by contacting the Company via the customer support information provided on Home Pixel.

1.4 Users can request the deletion of their personal data by using the "Delete Account" feature available on Home Pixel and following the Company’s instructions.

1.5 Users have the right to file complaints, report violations, take legal action, or seek compensation from the Company for damages resulting from violations of their personal data protection rights as outlined in these Terms of Use.

1.6 Users have the right to protect their personal data under the Civil Code and other applicable laws, and may request competent authorities or organizations to protect their civil rights in accordance with the provisions of the Civil Code.

1.7 Other rights as provided by law.

  1. Obligations of the User

2.1 Proactively protect your own Personal Data and have the right to request the Company to implement measures to safeguard it.

2.2 Respect and refrain from infringing upon the Personal Data of other Users on the Home Pixel platform.

2.3 Provide complete, accurate, and truthful Personal Data when using Home Pixel.

2.4 Comply with the legal regulations on Personal Data protection and actively participate in preventing violations related to Personal Data.

2.5 Fulfill all other obligations as prescribed by applicable laws.

  1. User Consent for the Processing of Personal Data on Home Pixel

The User’s consent to the processing of personal data on Home Pixel is deemed to be granted when the User selects the “Agree” checkbox and confirms by clicking the corresponding button, thereby acknowledging that they have read, understood, and accepted the terms of the Personal Data Protection Policy as set forth in these Terms of Use. Consent may also be granted by clicking the “Agree” button in response to any data processing notification presented by the Company during the course of using Home Pixel.

  1. Company’s Rights and Responsibilities in Personal Data Protection

4.1 The Company shall collect and process Users’ Personal Data in accordance with these Terms of Use and applicable laws.

4.2 The Company shall provide a communication channel for Users to submit requests related to their Personal Data, as outlined in Section 1 of these Terms.

4.3 The Company is responsible for maintaining the confidentiality of Users’ Personal Data in line with legal and regulatory requirements.

4.4 The Company shall implement appropriate security measures to protect Personal Data as required by law.

4.5 The Company is liable for any damages caused by its processing of Users’ Personal Data.

4.6 The Company shall delete Personal Data upon completion of the processing activity or upon the User’s request, unless retention is required by law or for fraud prevention, identity protection, or contract-related matters.

4.7 The Company shall fulfill any other legal obligations and exercise rights related to Personal Data protection as required by law.

4.8 Other rights and obligations as prescribed by law.

  1. Methods and Sources of Personal Data Collection

5.1 The Company collects Users’ Personal Data in accordance with this Terms of Use and in compliance with applicable laws.

5.2 Personal Data is collected through the following methods:

5.2.1 When Users enter their Personal Data into registration forms or other fields while using Home Pixel features.

5.2.2 When Users directly share their Personal Data through customer support channels, or when participating in promotions, contests, events, or engaging with the Company via official social media platforms.

5.2.3 Through the use of biometric identification features where applicable.

5.2.4 Automatically, via Home Pixel’s platform and tools, including transaction history, payment data, device information, user behavior, and communications through customer support or in-app messaging systems.

5.2.5 From authorized third-party partners such as marketing service providers, payment intermediaries, credit institutions, securities companies, and asset management firms, in accordance with applicable legal regulations.

  1. Use and Processing of Personal Data

6.1 The Company ensures that all personal data collected from Users is used and processed in accordance with these Terms of Use and applicable laws.

6.2 The Company may use, combine, and process Users' personal data for the following purposes ("Purposes"):

6.2.1 Verify User identity and authenticate personal information through electronic identification solutions or other valid methods.

6.2.2 Recommend and provide products and services to Users.

6.2.3 Introduce new features and services available on Home Pixel.

6.2.4 Provide customer support and care on Home Pixel.

6.2.5 Conduct marketing, advertising, and promotional activities for Home Pixel and/or its affiliates, marketing partners, and business partners.

6.2.6 Inform Users about promotions, media campaigns, products, or services on Home Pixel.

6.2.7 Support contract signing and execution of transactions on Home Pixel.

6.2.8 Facilitate and manage transactions made on Home Pixel.

6.2.9 Manage User activity and oversee User account operations on Home Pixel.

6.2.10 Handle User inquiries, feedback, or complaints while using Home Pixel.

6.2.11 Analyze and measure User behavior and engagement to improve existing products/services or develop new offerings that meet User interests—either from the Company or its partners.

6.2.12 Detect and prevent fraud, impersonation, or any activity that may cause damage to Users or the Company and violate the law.

  1. Transfer and Disclosure of Personal Data

The Company may share personal data with various parties to fulfill the purposes specified in this policy, including but not limited to:

7.1 With the Company, its parent company, affiliated entities, or authorized stakeholders involved in the business operations, products, or services of Home Pixel.

7.2 With service providers engaged to support the Company’s operations.

7.3 With advertising, marketing, media service providers, or platforms that manage affiliate or marketing programs.

7.4 With payment intermediaries and commercial banks where the User or Company holds accounts for deposit/withdrawal activities.

7.5 With consulting and market research agencies.

7.6 With data processing partners that have signed agreements with the Company.

7.7 With messaging service providers facilitating communication with Users.

7.8 With relevant government authorities in compliance with applicable laws.

  1. Storage and Deletion of Personal Data

8.1 Personal data will be stored in secure databases and regularly backed up. Sensitive data will be encrypted to ensure its security.

8.2 The Company will retain personal data for as long as the User is active on Home Pixel. This includes data retention after an account is locked or deleted due to violations, fraud, or impersonation, or during the data processing period, in compliance with applicable laws.

8.3 The Company is not responsible for unauthorized access to personal data if the User shares their information with others.

8.4 Personal data will be deleted upon the User’s request, once the data processing purpose is completed, or if the data is no longer needed, unless required by law or for fraud prevention or legal obligations related to the User's account.

8.5 The retention period for data ranges from 2 to 10 years, depending on the type of information and legal requirements.

  1. Transfer of Personal Data Abroad

To process personal data as described in Section 6, the Company may transfer User data to entities listed in Section 7, located outside of Vietnam. When transferring data abroad, the Company ensures that the recipient complies with Vietnamese legal requirements for data security and privacy.

  1. Duration of Personal Data Processing

Personal data is processed as soon as it is collected by the Company or its partners, and continues until all contractual obligations are completed, or the User requests data deletion or withdraws consent. The User understands and agrees that data processing for fraud prevention or legal compliance may involve reporting to authorities, in accordance with applicable laws, and is not limited by this policy.