Privacy Policy

(Effective from ….)

This Privacy Policy (“Policy”) is issued by _____ Company (“Meow Meow”) in compliance with the laws of Vietnam on personal data protection, including but not limited to the Law on Cybersecurity, the Law on Personal Data Protection, and relevant legal regulations.

This Policy governs the collection, processing, storage, and protection of personal data of users (“You”, “User”) when accessing and using the e-commerce platform developed by _____ Company Limited under the domain name _______ and the Meow Meow application on iOS and Android, owned and operated by _____ Company Limited (“Platform”) (collectively referred to as the “Services”). This Policy shall apply together with all notices, contractual terms, and consent terms relating to our collection, storage, use, disclosure and/or processing of your personal data and is not intended to override such notices or terms unless otherwise stated by us.

The terms “personal data”, “data subject”, “personal data processing”, “personal data controller”, “personal data processor”, “personal data controller and processor”, “third party”, and other related terms shall be interpreted in accordance with the Law on Personal Data Protection No. 91/2025/QH15 dated 26 June 2025 and its amendments or replacement regulations (if any).

ARTICLE 1. ROLE OF MEOW MEOW
1. Meow Meow acts as the personal data controller and processor for personal data collected during the operation of the Platform.

ARTICLE 2. TIME OF COLLECTION
1. Meow Meow may collect your personal data in the following circumstances:
(a) when you register, verify, log in to, or use your account on the Platform or use the Services;
(b) when you submit forms, registration information, support requests or documents related to the use of the Platform;
(c) when you enter into or perform any agreement or transaction with Meow Meow or other users through the Platform;
(d) when you interact or communicate with Meow Meow through telephone, email, messages, social media or other lawful communication channels;
(e) when you access or interact with the Platform, including through cookies and similar technologies;
(f) when you grant the Platform permission to access or collect data from your device;
(g) when you link your Meow Meow account with social media or other third-party accounts;
(h) when you conduct transactions, payments, shipping activities, product listings, order acceptance or other activities on the Platform;
(i) when you submit reviews, complaints, dispute requests or participate in programs organized by Meow Meow;
(j) when you voluntarily provide personal data to Meow Meow for any lawful reason;
(k) when you engage in other activities on the Platform resulting in lawful creation or collection of personal data.

2. Your personal data may be collected from:
(a) directly from you;
(b) affiliates, partners or service providers;
(c) third parties related to transactions between buyers and sellers;
(d) publicly available lawful sources or competent authorities.

3. If you provide personal data of another person, you represent that you have obtained the lawful consent of such individual.

ARTICLE 3. PERSONAL DATA COLLECTED
1. Meow Meow may collect and process the following categories of personal data:
• full name;
• email address;
• date of birth;
• billing and/or shipping address;
• bank account and payment information;
• personal tax code;
• telephone number;
• gender;
• device-related information;
• network and contact information;
• images, audio and video;
• identity information issued by competent authorities;
• communication preferences and history;
• transaction and usage information;
• location data;
• information relating to use of the Platform and Services;
• aggregated user content data.

2. You undertake that the information provided is accurate, complete and up to date.

3. Where you connect your account with social media or external accounts, Meow Meow may access the personal data voluntarily shared with such providers in accordance with their policies.

4. You may opt out of providing certain personal data by contacting our Personal Data Protection Officer. However, refusal may affect your ability to use the Services.

ARTICLE 4. COLLECTION OF OTHER DATA
1. When you access the Platform, your device may automatically transmit information including:
• IP address;
• operating system, browser type and device type;
• device specifications and configurations;
• device identifiers;
• referral URL;
• accessed pages and content;
• access time, duration and frequency;
• cookies and similar technologies.

2. The mobile application may collect location data through GPS, Wi-Fi, Bluetooth or similar technologies where permitted by you.

3. Interaction with advertisements, software or content on the Platform may also generate technical data used for analytics and service improvement.

ARTICLE 5. COOKIES
1. Meow Meow and authorized service providers may use cookies and similar technologies to collect information regarding your use of the Platform. Such information may be linked to your personal data and used for:
• maintaining platform security and functionality;
• remembering login status and preferences;
• analytics and performance improvement;
• personalized content and recommendations;
• advertising measurement where permitted by law.

2. You may disable cookies through browser or device settings, although some Platform functions may become unavailable.

ARTICLE 6. PURPOSES OF PROCESSING
1. Meow Meow may process your personal data for the following purposes:
(a) processing transactions and requests;
(b) operating and maintaining the Platform;
(c) managing purchases, payments and deliveries;
(d) enforcing the Platform rules and policies;
(e) ensuring safety and protecting lawful interests;
(f) identity verification, KYC and fraud prevention;
(g) evaluating eligibility for financial services;
(h) system maintenance and technical support;
(i) customer service and dispute resolution;
(j) communicating with you regarding the Platform;
(k) enabling user interaction;
(l) research, analytics and service improvement;
(m) internal audits and assessments;
(n) marketing and promotional activities subject to applicable law and consent requirements;
(o) loyalty and partnership programs;
(p) compliance with legal obligations;
(q) reporting and record keeping;
(r) fraud investigation and risk control;
(s) data storage, backup and recovery;
(t) mergers, acquisitions or restructuring activities;
(u) other purposes notified to you at the time consent is sought.

2. Meow Meow may access, store, use or disclose your personal data where necessary to comply with legal obligations, enforce policies, resolve disputes or protect rights and safety.

3. If additional purposes arise, Meow Meow shall notify you and obtain consent where required by law.

ARTICLE 7. SHARING OF PERSONAL DATA
1. Meow Meow may disclose or transfer personal data to:
(a) affiliates and related companies;
(b) other users involved in transactions;
(c) service providers and contractors;
(d) competent authorities;
(e) parties involved in mergers or business transfers;
(f) other third parties with your consent or as required by law.

2. Aggregated or anonymized data may be shared with advertising or analytics partners.

3. Where permitted by law, Meow Meow may process personal data without consent on lawful bases including contractual necessity, legal obligations or legitimate interests.

4. While Meow Meow applies reasonable security measures, absolute security cannot be guaranteed.

5. Users receiving personal data of other users through the Platform must comply with applicable personal data protection laws.

ARTICLE 8. DISCLAIMER REGARDING THIRD-PARTY WEBSITES
1. The Platform may contain links or integrations with third-party websites or services. Meow Meow does not control such third parties.

2. Meow Meow shall not be liable for losses arising from third-party processing of personal data except where otherwise required by law.

3. Users should review the privacy policies of third parties before providing personal data.

ARTICLE 9. CROSS-BORDER TRANSFER
1. Your personal data may be transferred outside your country for one or more processing purposes in compliance with applicable data protection laws.

ARTICLE 10. DATA RETENTION
1. Personal data shall only be retained as long as necessary for the processing purposes or as required by law.

2. Personal data is generally retained throughout the duration of your account use and up to five (05) years thereafter unless longer retention is legally required.

3. Following account deactivation, Meow Meow may retain data for three (03) months for account restoration, fraud prevention and verification purposes.

4. Longer retention may apply where necessary for legal compliance, dispute resolution or protection of lawful interests.

ARTICLE 11. PERSONAL DATA PROTECTION MEASURES
1. Meow Meow implements appropriate technical and organizational measures to protect personal data from unauthorized access, use, disclosure or destruction.

2. Users are responsible for safeguarding account credentials and notifying Meow Meow of suspected unauthorized access or data incidents.

3. Meow Meow shall delete, anonymize or destroy personal data where legally required or no longer necessary.

ARTICLE 12. RIGHTS OF DATA SUBJECTS
1. Under applicable law, users have the following rights:
(a) right to be informed;
(b) right to consent;
(c) right to withdraw consent;
(d) right to access;
(e) right to amend or supplement data;
(f) right to deletion;
(g) right to restrict processing;
(h) right to object;
(i) right to request provision of data;
(j) right to complain or initiate legal proceedings.

2. Requests may be submitted through the contact details below, and identity verification may be required.

3. Meow Meow shall respond to lawful requests within the timeline required by law.

4. Exercising certain rights may affect your ability to use parts of the Platform.

ARTICLE 13. CONTACT
For any questions, complaints or requests relating to this Privacy Policy or personal data processing, please contact:

• Personal Data Protection Officer
• Email: [email protected]

CONSENT CHECKBOX

___ I have read, understood and agreed to Meow Meow processing my personal data in accordance with this Privacy Policy, including the categories of data processed, purposes of processing, and my rights and obligations as a data subject. By ticking the above box, I confirm that:
(i) I voluntarily consent to Meow Meow, as the personal data controller and/or controller and processor, collecting, using, storing and processing my personal data;
(ii) I have been fully informed of the categories of personal data processed, the purposes of processing, and my rights and obligations as a data subject;
(iii) I understand that this consent remains effective until withdrawn or otherwise provided by law;
(iv) I understand that failure to tick the consent box or silence shall not constitute consent and may result in inability to use part or all of the Services.