PRIVACY POLICY
1. User Consent
COSMO respects your privacy and is committed to protecting your personal data in compliance with Vietnamese legal provisions. This Privacy Policy outlines how COSMO collects, processes, and safeguards your personal data when you access or interact with our Website or Application (App). This policy applies to all data collected or provided by you in connection with your use of both the Website and App.
This Privacy Policy is established in accordance with Decree No. 13/2023/ND-CP on personal data protection and other relevant legal provisions. You are responsible for carefully reviewing its contents and regularly checking for updates. By accessing the Website, using the App, or consenting to COSMO's collection and processing of your personal data, you fully accept the terms of this Privacy Policy. If you do not agree with any provisions, you must cease accessing the Website or App.
For clarity, COSMO reserves the right to suspend or terminate your access to the Website or App if you refuse to accept these terms without prior notice. Access to the Website or App is granted once COSMO obtains your consent for personal data collection and processing in line with this Privacy Policy.
2. Definitions
2.1. Personal Data: Information in the form of symbols, scripts, numbers, images, sounds, or similar formats in an electronic environment, associated with or identifying a specific individual. It includes both basic personal data and sensitive personal data.
2.2. Basic Personal Data: Includes but is not limited to:
Full name, middle name, birth name, and any other names;
Date of birth, date of death, or date of disappearance;
Gender;
Place of birth, permanent and temporary residence, current address, and contact address;
Nationality;
Individual images;
Telephone number, identity card number, passport number, driving license number, tax identification number, and social insurance number;
Marital status;
Family relationship information (e.g., parents, children);
Digital account details and personal data reflecting online activities;
Other identifiable personal information not classified as sensitive.
2.3. Sensitive Personal Data: Information closely linked to an individual's privacy, which, if breached, may directly impact their legal rights and interests. This includes:
Political or religious beliefs;
Health status and medical records (excluding blood type);
Racial and ethnic origin;
Genetic characteristics;
Physical attributes and biometric data;
Sexual life and orientation;
Criminal records;
Financial data;
Geolocation data;
Any other personal data deemed sensitive by law.
2.4. Processing of Personal Data: Any action affecting personal data, such as collection, storage, analysis, modification, disclosure, encryption, sharing, transmission, deletion, or destruction.
3. Collection of Personal Data
COSMO may collect your personal data, either directly or indirectly, during your access and use of the Website or App. This includes:
Information you provide when registering an account, making purchases, or contacting customer support;
Data collected automatically, such as IP address, device information, and browsing behavior;
Data obtained from third parties, such as payment processors or social media platforms (with your consent).
4. Notification Regarding Data Processing
4.1. COSMO will notify you prior to processing your personal data.
4.2. The notification will specify:
The purpose of processing;
The type of personal data involved;
The methods used for processing;
The organisations or individuals related to the processing;
Possible risks and consequences;
The start and end date of processing.
4.3. The notification will be presented in a format that allows for printing, copying, or electronic verification.
4.4. COSMO is not required to notify you in cases where:
You are already aware of and have explicitly agreed to the processing;
Data is processed by authorised state agencies for official purposes.
5. Processing of Personal Data Without User Consent
COSMO may process your personal data without consent in the following cases:
Emergencies to protect life, health, or safety;
Compliance with legal obligations;
National security or defence emergencies;
Fulfilment of contractual obligations;
Supporting state authority operations.
6. Use of Personal Data
COSMO uses your personal data to:
Improve services and optimise your experience on the Website and App;
Provide customer support and verify identity;
Send promotional offers, service updates, and marketing communications;
Conduct business operations and security checks.
7. Provision of Personal Data
7.1. You may request COSMO to provide your personal data.
7.2. COSMO may share your data with:
Organisations or individuals with your consent;
Authorised representatives or third parties as required by law.
7.3. Data provision will be completed within 72 hours of your request, unless otherwise stipulated by law.
7.4. COSMO will not provide data if it:
Harms national security or public safety;
Affects the safety or health of others;
Is not consented to by you.
8. Correction of Personal Data
You have the right to access and correct your personal data. COSMO will process correction requests as soon as possible or within 72 hours of receipt.
9. Retention, Deletion, and Destruction of Personal Data
9.1. You may request COSMO to delete your personal data if:
It is no longer necessary for the agreed purpose;
You withdraw consent;
Data is processed unlawfully.
9.2. Deletion will not apply if:
Prohibited by law;
Required for legal obligations or state authority operations.
9.3. Data deletion will be completed within 72 hours of your request.
10. Protection of Personal Data
COSMO treats your personal data as private and confidential. We implement security measures to protect your data from unauthorised access, use, or disclosure. However, no system is entirely secure, and you should be aware of potential risks, such as cyberattacks or phishing.
11. Users’ Rights
You have rights regarding your personal data under Decree No. 13. To exercise these rights, withdraw consent, or lodge a complaint, contact COSMO at:
Email: [Insert contact email]
Phone: [Insert contact number]
12. Withdrawal of Consent
You may withdraw consent for data processing at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
13. Organisations and Individuals Authorised to Process Personal Data
The following entities are authorized to process Users’ Personal Data:
COSMO Club, including its personnel assigned to handle Users’ Personal Data.
Parent company, subsidiaries, and affiliated companies of Top Mix Consultants JSC.
Partners, agents, suppliers, contractors, and consultants working with COSMO Club or Top Mix Consultants JSC, where sharing or disclosing data is necessary for COSMO Club to fulfill its obligations to Users.
Companies providing payment services and related transaction services through COSMO Club’s website, app, or e-commerce platform.
Service providers supplying products or services to COSMO Club and/or Top Mix Consultants JSC, including but not limited to accounting, auditing, valuation, IT services, marketing, market research, training, and legal services.
Entities involved in business transactions such as mergers, acquisitions, sales, transfers, or assignments of business assets, shares, or capital contributions of COSMO Club and/or Top Mix Consultants JSC.
Third-party data processors under agreements with COSMO Club and/or Top Mix Consultants JSC, including research firms, survey agencies, and rating companies.
Parties authorized by the User or those with whom COSMO Club and/or Top Mix Consultants JSC has a legal basis to share Users’ Personal Data.
Government authorities or other third parties to whom COSMO Club and/or Top Mix Consultants JSC is legally required or permitted to disclose personal data under applicable laws and/or legal agreements.
14. Storing and Protecting Personal Data
● Users’ Personal Data is stored and processed from the moment COSMO Club lawfully collects it and has the appropriate legal basis for processing in accordance with applicable laws.
● COSMO Club commits to storing and processing Users' Personal Data solely for the purposes outlined in this Policy.
● Processing will cease when:
(i) A User requests COSMO Club to stop processing their data;
(ii) COSMO Club no longer has obligations to provide services to the User; or
(iii) Another legally prescribed period applies, except where continued storage is necessary to fulfill the purposes stated in this Policy, comply with legal obligations, or meet requests from competent state authorities.
COSMO Club implements various security measures to protect Users’ Personal Data from unauthorized access, use, or disclosure. However, no system is entirely secure. While COSMO Club will make every reasonable effort to protect Users’ data, Users should be aware of potential risks, including but not limited to:
(i) Hardware or software failures during data processing that may result in data loss;
(ii) Security vulnerabilities beyond COSMO Club’s control, such as cyberattacks leading to data breaches;
(iii) Users unintentionally disclosing personal data due to negligence or falling victim to phishing, malware, or fraudulent websites.
(i) Users’ Personal Data is stored and processed from the moment COSMO Club legally.
15. Changes in Business Ownership and Control
If COSMO undergoes business changes (e.g., sale or transfer of control), your personal data may be transferred to the new owner, who will use it in accordance with this Policy.
16. Cookies & Privacy
When you access the Website or App, cookies may be stored on your device. You can manage cookie preferences through the Cookie Settings page. Essential cookies, required for system functionality, will always remain enabled.
17. General Terms
You may not transfer your rights under this Policy to another party.
If any provision of this Policy is found invalid, the remaining provisions will remain valid and enforceable.
By accessing or using the COSMO Club website and app, Users confirm that they have thoroughly read, clearly understood their rights and obligations, and agree with the content of this Policy, including the Personal Data Processing Notice stipulated in Article 13 of Decree 13/NĐ-CP/2023 and any amendments and supplements from time to time, which are posted on COSMO Club’s website and app. Therefore, COSMO Club does not need to take any additional notification measures regarding the processing of Users’ Personal Data.
Any matters related to personal data processing that are not specified in this Policy will comply with the current legal regulations. For any questions, please contact us at:
COSMO Club
Email: contact@cosmosaigon.com
Phone: (+84) 901 330 909
Address: First Floor, Rex Hotel 141 Nguyen Hue Boulevard, District 1, Ho Chi Minh City
Last updated: 10th Apr 2025