1.2. This policy applies to any person (hereinafter referred to as “The Customer”) who accesses the website, and/or uses the products and/or services of, and/or performs transactions with WMC Group (hereinafter collectively referred to as the “Service”) in connection with the collection, storage and use of customers’ personal information.
1.3. This policy applies to all WMC Group Services, whether online through the WMC Group website and/or directly at WMC Group.
2.1. Collect information only for the purposes set forth in Section 3 of this Policy;
2.2. Inform The Customer about the purpose for which information is to be collected and only use the information for this purpose, except for exceptions under this Policy, the use of information for other purposes shall be notified and subject to The Customer’s consent;
2.3. This policy applies to the aggregated Services of WMC Group, but from time to time, for each Service or portion of the Service, subject to the specificity and requirements of the Service, WMC Group may modify/supplement the content of this Policy to apply specifically to those particular Services;
2.4. Depending on the situation and actual security needs, WMC Group may modify this Policy without notice or consent of The Customer. Updating the contents of the policy is stipulated in Item 15 of this Policy;
2.5. Whenever The Customer accesses, uses the Services provided by WMC Group, the The Customer hereby agrees to the terms and conditions set forth by WMC Group in this Policy (including supplements or modifications from time to time);
2.6. WMC Group will always provide the option of deciding whether to provide or not to provide The Customer Information. Where The Customer chooses not to provide or provide inadequate information, there may be some services, transactions that can not be performed or The Customer’s interests are subject to certain restrictions.
WMC Group is committed to ensure the transparency of the collection and use of personally identifiable information (PII) provided by, or collected from The Customer while using our websites, products and services.
3.1. We collect The Customer information primarily for the purpose of supporting, maintaining contact with The Customers such as:
a) Providing services such as processing transactions (eg, booking, making inquiries, or completing ordering information.)
b) Maintaining communication with customers, answering customer queries related to the services of WMC Group.
c) Marketing and communications with The Customer in relation to our products and services as well as our strategic marketing partners and other trusted third parties (Marketing and Advertising).
d) Performing market research via surveys to better serve The Customer’s needs, improve the effectiveness of our websites, The Customer’s hotel experience, our various types of communications, advertising campaigns, and/or promotional activities.
3.2. We collect the information for the purpose of checking and upgrading service quality such as:
a) Check The Customer access, using WMC Group service;
b) Analysing and optimizing service group of WMC;
c) Upgrading service quality of WMC Group;
3.3. Beside of the mentioned purposes in 3.1 and 3.2, WMC Group can also collect the Information to other purposes entries to be non with a law format that as: member registration, submitting a job application, replying from The Customer’s requests, requiring from legal authorities and so on.
4.1. The type of personal indentifiable information we collect may include but not limited to The Customer’s name, home address, work place and e-mail address, telephone number, fax number, credit card information, date of birth, gender and lifestyle information such as accommodation preferences, leisure activities, name – age of the child, and other information needed to meet special requirements (eg, health conditions that require special accommodations when the customer agrees to provide it.)
4.2. We may also collect The Customer’s personal non-personally identifiable information, such as The Customer’s use of the websites, communication preferences, travel habits, data relative to The Customer’s stays and responses to promotional offers and surveys.
4.3. For each Service or other specific collection purposes, WMC Group may, from time to time, request The Customer to provide additional information to ensure The Customer’s use of service or to ensure communication, transactions between WMC Group and The Customers are smooth and convenient for both parties.
In order to ensure that the information collected is complete and accurate, WMC Group may, at its sole discretion, choose to use individually or aggregated collecting methods as follows:
5.1. WMC Group recommends that customers provide information in the following cases:
a) Some of the Services of WMC Group allow/request The Customer to provide personal profiles or create a new account to best use these Services. WMC Group may require The Customer to provide the information referred to in Section 4 above in order to meet The Customer’s use of the Services.
b) In case The Customer requests WMC Group to respond to enquiries related to the Services of WMC Group or The Customer requests WMC Group to provide the Services (for example: purchase, online services, inquiries support …), WMC Group can request customers to provide information to handle customer requests quickly and accurately;
c) The circumstances require collection of other information, depending on the nature of the type of Service that The Customer elects and require to provide information of that Service type.
5.2. WMC Group self-collect information
a) Collecting information from third-party sources
WMC Group may receive The Customer information that is publicly available, legally available on any third party’s source of information, or receive The Customer Information from third parties when WMC Group engages in such transactions which there is a transfer of such information.
b) Collection during the implementation of the Service
During the implementation of the Service, WMC Group may also collect The Customer Information in other appropriate ways that The Customer agrees with such collection method.
Some of the Services of WMC Group allow The Customer to contact the third party, such communications will be communicated and the information generated during that communication may be stored on the WMC Group system.
5.3. Consolidated Information
WMC Group may consolidate The Customer Information that WMC Group derives from the collection by the various means referred to in this Section as a complete operation of the Information to serve the purposes outlined in the Policy without the prior consent of the The Customer. However, The Customer always has the right to opt-out or to cancel his / her Information pursuant to Section 8.6 of this Policy.
6.1. Information used for the provision and performance of the Service to The Customer
a) Personal information collected will only be used within WMC Group to provide and perform the Services to The Customer. When necessary, we may use this information to contact the The Customer directly in the form of: open letters, orders, thank letters, information about new promotions and services.
b) Only employees who are in charge of and/or directly involved in the management of information to serve as a basis for the provision and performance of the Services to the The Customer shall be given access to The Customer’s personal information.
6.2. Information to be shared or provided to a third party:
We may share or be required to provide The Customer’s personal information to third parties, including:
• Payment processors for secure credit card payment transaction
• Hosting services
• Email service providers to send The Customer emails pertaining to The Customers’ booking. Such providers may send emails of a marketing nature if The Customer have agreed to receive such newsletters and will track some performance indicators, such as open and click rates.
• Advertising partners who may use email address, cookies and other tracking technologies, such as web beacons, to gather information about The Customer’s activities on our website and other sites to provide The Customer with targeted advertising based on The Customer’s browsing activities and interests.
• Our business partners, suppliers, and sub-contractors, for the performance of any contract we enter into with them. We may also share The Customer’s data with analytics and search engine providers that assist us in the improvement of our website.
• Provided to a third party or to the legal authorities when required by the legal authorities or otherwise under the law or WMC Group has grounds for the Legal Authority when we believe that we are legally authorized or required to do so or when it is necessary to do so to protect the rights, property or safety of the The Customer or the safety of WMC Group, employees and users from fraudulent, abusive, inappropriate or illegal use of our services.
• For the development of business operations or in the event of force majeure, WMC Group may be required to carry out reorganization, transfer, dissolution or bankruptcy of the company, in which case the inheritance or transfer of WMC Group may receive The Customer Information in lieu of WMC Group to continue providing and performing the Services to The Customer. This involves or is in the process of negotiating, merging or selling the Company property.
• The other parties upon the agreement or under the guidance of The Customer.
The Customer’s personal data will be retained only in the necessary time for the purpose for which the Information was collected or as required by the Contract or as required by applicable law or until the request is canceled from The Customer or data is no longer relevant to the purpose of the original collection or processing. Please note that we are not able to delete The Customer’s entire historical data in some cases. For example, we are required to retain certain records for financial reporting and compliance reasons.
8.1. Thorough understanding of this Policy before using, accessing the WMC Group’s Services, the use of WMC Group’s Services, is also a confirmation that The Customer have thoroughly reviewed and agreed to this Policy.
8.2. To provide accurate, lawful, and non-misleading information to WMC Group when requested and agreed to provide and to notify us of any changes. The Customer will be fully responsible (in all cases, no affiliation to WMC Group in whole or in part) if:
a) The Customer’s performance of the Service is interrupted, unable to perform; or transactions between WMC Group and The Customer, between WMC Group and a third party, between The Customer and a third party is interrupted or unenforceable from the use of Incomplete or Supplied information.
b) The Customer information provided to WMC Group is inaccurate, unlawful, damaging to The Customer, WMC Group and any Third Party;
8.3. Do not use any programs, tools or other forms to interfere with the system or alter the data structure of the Service, the interface of the website, the features of the WMC Group website.
8.4. Do not share, provide information in detail relative to performing the transaction and/or use our Service with anyone except for WMC Group. In this case, WMC Group will not be responsible for any disclosure of information and damage that The Customer can suffer in sharing, exchanging and providing The Customer’s information.
8.5. Do not distribute, propagate or promote any activity that interferes with, disrupts or infiltrates the data of the website system under the control of WMC Group.
8.6. The Customer has access to his / her Information and has the right to self-correct errors in his /her personal data or to update or supplement the information stored on WMC Group systems. The Customer also has the right to delete personal data on the website itself or to request that WMC Group discontinue use of personal data for marketing purposes by sending a request to discontinue the activity receiving the notice or information from the website.
8.7. WMC Group is concerned about problem, spam or fake email. WMC Group will only send e mail to The Customer when and only if The Customer has registered or used the service from our systems. Therefore, in order to keep The Customer’s information confidential, The Customer agrees not to sell, lend, lease the email of the Company or to rent or borrow emails from third parties. If the customer receives unsolicited email from our systems due to an unintended cause, please click on the link to refuse to receive this email attached or delete this email from your system and notify directly to the website management board.
9.1. As part of our commitment to provide information to The Customer, we may send The Customer a letter, e-mail, telephone or other communications to inform The Customer about new products and services or promotions, events, or other related information that The Customer may be interested in. The Customer may also receive mail or other information from carefully selected third parties. We always provide The Customer the option of refusing any or all of the information by following the instructions contained in our email or other communications or by contacting us directly.
9.2. We want to inform all our customers and visitors to be able to take advantage of the benefits provided by us and our strategic marketing partners. Certain data security regulations may require The Customer’s permission before we send The Customer information that The Customer have not requested yet.
9.3. In some cases, The Customer’s consent will be implied when The Customer requests service or make a transaction. For example, we may collect and use personally identifiable information that The Customer voluntarily provides, or data, behavior information collected during the transaction. In addition, The Customer’s agreement will be defaulted when The Customer fill in the transaction information that we send at The Customer’s request.
9.4. In certain circumstances, we will seek The Customer’s express permission when we collect information that is regarded under certain data privacy regulations to be sensitive in nature and only be collected with The Customer’s consent (e.g., information revealing racial or ethnic origin, political opinions, or health conditions).
10.1 WMC Group is committed to the security of The Customer’s information in accordance with the provisions of this Policy and the provisions of the law.
10.2. WMC Group are always careful to protect the user’s information. When users provide sensitive information through the website, their information is protected both online and offline.
10.4. The servers store personal identification information stored in a secure and carefully locked environment.
10.5. WMC Group will apply appropriate technical and security options and solutions to best protect The Customer Information. However, note that while WMC Group makes reasonable efforts to protect The Customer Information, no site, Internet connection, computer system or wireless connection is absolutely. Therefore, WMC Group can not make a firm commitment that the information provided to WMC Group will be kept absolutely secure, and WMC Group can not be held liable in the event of illegal access, leakage of The Customer Information that is beyond the control of WMC Group. If The Customer disagrees with the terms described above, WMC Group recommends that The Customer should not send Information to WMC Group.
WMC Group may provide links to other websites (not controlled by WMC Group) to facilitate The Customer’s experience. Therefore, WMC Group will not be responsible for the safety or security of any Information collected by such Third Parties without being executed on the WMC Group website to manage and/or to control. We encourage The Customer to seek information about the privacy policies and regulations of linked websites to better understand the collection, use, and storage of information.
Our websites are not intended for children and we do not intentionally solicit or collect personal information from individuals under the age of 18. If we are notified or otherwise discover that a minor’s personal information has been improperly collected, we will take all commercially reasonable steps to delete that information. In limited instances, we may have a campaign or programme targeted towards children. In these instances, details on the information practices will be presented within the terms and conditions of the programme.
14.1. When The Customer feels his / her personal information has been missued The Customer must send a complaint to email email@example.com or call to +84 28 3838 8900 to complain and provide relevant evidence to the the website management. The management commits to respond immediately or at the latest within 72 (seventy-two) working hours from the time of receipt of the complaint.
14.2. When WMC Group discovers that The Customer’s personal information on our system is being infringed by another person, we will endeavor to contact The Customer and / or other authorized authority within 72 (seventy-two) hours for the The Customer and / or the competent authority to consider the action plan, unless such infringement does not jeopardize the rights and property of the individual of The Customer. We will only deal with the information that has been infringed, unless advised otherwise by a competent authority – i.e. Vietnamese Police, Government or similar agency.
WINDSOR MANAGEMENT CORPORATION GROUP (WMC Group)
Level 10, No. 8 Nguyen Hue, District 1, Ho Chi Minh City (Saigon), Vietnam