PRIVACY POLICY

Effective Date: March 28, 2025

Social Boost Asia ("We", "Us", "Our") is committed to respecting and protecting the privacy of all users ("You", "User") accessing and using the website socialboost.asia ("Website") and related services ("Services"). This Privacy Policy ("Policy") explains how we collect, use, store, protect and (in certain circumstances) disclose your personal information.

By accessing the Website, registering an Account or using the Services, you agree to the terms described in this Policy and the regulations regarding the processing of your personal information. If you do not agree with this Policy, please do not use our Services.

1. Scope of Application

This Policy applies to all personal information we collect from Users through the Website and Services, regardless of the method of access (computer, mobile device, etc.). This policy does not apply to third-party websites or services that you may access through links from our Website.

2. Information We Collect

We collect the following types of information to provide and improve our Services:

• 2.1. Personal Information You Provide:
  • Account Registration Information: Username, email address, phone number, password (see Section 5 regarding password security).
  • Contact Information: When you contact customer support or send feedback (may include name, email, content of communication).
  • Order Information: URL of the post/page/social media channel requiring engagement, service type, quantity.
  • Payment Information: We may collect necessary information to process payments (e.g., bank account info, e-wallet). However, for credit/debit card transactions, card details are typically processed directly by reputable third-party payment gateways and we do not store your full card number.
• 2.2. Automatically Collected Information:
  • Log Data: When you access the Website, our servers automatically record information that your browser sends. This data may include IP address (may be partially anonymized), browser type, browser version, pages you visit on our Website, time and date of access, time spent on those pages and other statistics.
  • Service Usage Data: Information about how you interact with the Services, such as features used, orders placed, transaction history.
  • Cookies and Similar Technologies: We use cookies and similar tracking technologies to collect information about your browsing activity, maintain login sessions, personalize experience and analyze Website performance. (See Section 8 for more details).

3. Purpose of Information Use

We use collected information for the following purposes:

• Provide, operate and maintain Services (user authentication, order processing, transaction execution).
• Manage your Account.
• Improve, personalize and expand Services (analyze usage trends, develop new features).
• Communicate with you: Send Account notifications, Service updates, respond to support requests, send marketing information (if you agree and have the right to opt-out).
• Prevent fraud, abuse and ensure security and safety for the system and Users.
• Comply with legal obligations and applicable regulations of Vietnam.
• Resolve disputes, enforce our agreements and policies.

4. Legal Basis for Personal Information Processing (Under Vietnamese Law)

The processing of your personal information is carried out based on the following legal bases, complying with Decree 13/2023/ND-CP on Personal Data Protection and related regulations:

• Your Consent: When you register an account, place an order, or agree to receive marketing information. You have the right to withdraw consent at any time.
• Contract Performance: When processing is necessary to provide the Services you requested (e.g., order processing, account management).
• Legal Obligation: When we need to process information to comply with Vietnamese legal requirements (e.g., requests from competent state authorities).
• Our Legitimate Interests: When processing is necessary for our legitimate interests (e.g., ensuring system security, preventing fraud, analyzing service improvement), provided that such interests do not infringe upon your fundamental rights and legitimate interests.

5. Information Security and Password Encryption

We value the security of your personal information and apply reasonable technical, administrative and physical measures to protect that information from unauthorized access, use, alteration or destruction.

• Transmission Encryption: All communication between your browser and our servers is encrypted using Secure Socket Layer (SSL) or Transport Layer Security (TLS) technology.
• Advanced Client-Side Password Encryption: We are committed to protecting your password at the highest level. When you create or change a password, the password will be encrypted (hashed) right on your browser using strong, modern encryption algorithms (e.g., bcrypt or Argon2) before being sent to our servers. This means your original (plaintext) password is never transmitted over the network or stored on our servers, significantly reducing the risk of password exposure even in the event of a system compromise. We only store the hashed form of the password.
• Access Control: Access to personal information is strictly limited to employees or partners who need to know that information to perform their duties and they must comply with strict confidentiality obligations.
• Firewall and Monitoring: We use firewalls and security monitoring systems to detect and prevent unauthorized access.
• Security Assessments: We regularly review and update security measures to cope with new threats.

Although we make every effort to protect your personal information, no electronic transmission or storage system is 100% secure. Therefore, we cannot guarantee absolute security.

6. Sharing and Disclosure of Information

We commit not to sell, rent or trade your personal information to third parties for marketing purposes without your explicit consent. We only share personal information in the following limited circumstances:

• Service Providers: We may share information with trusted third-party service providers to support our business operations (e.g., payment processing, data hosting, website analytics, email delivery, customer support). These providers are only allowed to use your information according to our instructions and must comply with equivalent confidentiality obligations.
• Legal Requirements: We may disclose your information if required by law, court, or competent state authorities of Vietnam, or if we believe that such disclosure is necessary to:
  • Comply with legal process.
  • Protect the rights, property or safety of Social Boost Asia, our Users or the public.
  • Detect, prevent or resolve fraud, security or technical issues.
  • Enforce our Terms of Service.
• Business Transfers: In the event of a merger, acquisition, restructuring, sale of assets or bankruptcy, your information may be transferred as part of business assets, but the recipient will be required to comply with commitments in this Privacy Policy (or notify you of new policy).
• With Your Consent: We may share information in other ways if we have explicit consent from you.
• Aggregated/Anonymized Data: We may share aggregated or anonymized non-personally identifiable data for analysis, research or reporting purposes.

7. Data Retention

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Criteria for determining retention periods include:

• The time you maintain an Account with us.
• Necessity to provide Services to you.
• Legal, tax or accounting obligations we must comply with.
• Necessity to resolve disputes or enforce agreements.

When personal information is no longer needed for the above purposes, we will securely delete or anonymize that information.

8. Cookies and Tracking Technologies

• What are cookies? Cookies are small text files stored on your device when you visit websites. They help the website remember information about your visit, making the next visit easier and the website more useful.
• How we use Cookies:
  • Essential Cookies: Necessary for basic Website operation, such as maintaining login sessions, security.
  • Performance/Analytics Cookies: Help us understand how Users interact with the Website (e.g., Google Analytics) to improve performance.
  • Functional Cookies: Remember your choices (e.g., language, interface) to provide a more personalized experience.
  • Marketing Cookies (if any): May be used to show ads more relevant to your interests (with your consent).
• Cookie Management: Most browsers allow you to control cookies through settings. You can refuse or delete cookies, but this may affect the ability to use some features of the Website.

9. Your Rights Regarding Personal Information

According to Vietnamese law, especially Decree 13/2023/ND-CP, you have the following rights regarding your personal information:

• Right to be informed: Know about the processing of your personal data.
• Right to consent: Agree or disagree to allow processing of personal data.
• Right of access: View, access your personal information that we store.
• Right to withdraw consent: Withdraw consent granted for data processing.
• Right to delete data: Request us to delete your personal information in certain circumstances.
• Right to restrict processing: Request us to suspend data processing in certain circumstances.
• Right to data portability: Request us to provide your personal data to you.
• Right to object to processing: Object to our processing of your data to prevent or stop such behavior.
• Right to complain, denounce, sue: Exercise legal rights when there is a violation of personal data protection regulations.
• Right to claim damages: Claim compensation when actual damage is caused by violation of personal data protection regulations.

To exercise these rights, please contact us using the information in Section 13. We may require you to verify your identity before processing the request.

10. Children's Privacy

Our Services are not intended for persons under 18 or the minimum legal age to enter into a contract in your country. We do not knowingly collect personal information from children. If you are a parent or guardian and discover your child has provided personal information to us, please contact us immediately. If we become aware we have collected personal information from children without parental/guardian consent, we will take steps to delete that information.

11. Compliance with Vietnamese Law

Social Boost Asia commits to operating and processing User's personal data in strict compliance with applicable laws of the Socialist Republic of Vietnam, including but not limited to:

• Cybersecurity Law No. 24/2018/QH14.
• Decree No. 13/2023/ND-CP dated April 17, 2023 of the Government on Personal Data Protection.
• Law on Electronic Transactions No. 51/2005/QH11 (and amendments).
• Law on Information Technology No. 67/2006/QH11.
• Law on Protection of Consumers' Rights No. 59/2010/QH12.
• Other relevant legal documents.

We are subject to supervision and management by competent state authorities in Vietnam regarding personal data protection and cybersecurity.

12. Changes to Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in practices or new legal requirements. We will notify you of any material changes by posting the new Policy on the Website and updating the "Effective Date" at the top. We encourage you to review this Policy periodically. Your continued use of the Services after changes take effect constitutes your acceptance of the updated Policy.

13. Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or how we process your personal information, please contact us via:

• Email: [email protected]
• Contact form on website: https://socialboost.asia/vi-vn/lien-he
• Address: 88 Market Street, CapitaSpring, #21-01

We will try to respond to your request as soon as possible and in accordance with the law.