PRIVACY POLICY

2.1. By accessing or using our Digital Properties you agree to this Privacy Policy.

2.2. If you do not agree to this Privacy Policy, you must not access or use the Digital Properties.

3.1. We are committed to protecting your Personal Data in compliance with the laws of the Socialist Republic of Vietnam.

3.2. This Digital Property serves a single purpose: To make our works accessible to others. To do that we try to ensure Digital Property visitors, prospective customers, buyers and clients receive relevant and, where possible, personalised information. We collect, use, and share information about you to fulfill our purpose, meet (and hopefully exceed) your expectations, and provide value to our stakeholders and the communities we serve.

3.3. We may share certain Personal Data with selected Partners to provide services, support advertising, or measure performance. Some Partners may independently use such data to improve their advertising models.

3.4. This Privacy Policy explains what Personal Data we collect, why we collect it, how we use it, when we share it, how we protect it, and the rights available to you.

4.1. This Privacy Policy applies to all interactions you have with us, including all communication and correspondence, and your use of our Digital Properties unless the specific property has its own privacy policy.

4.2. We cannot guarantee the protection of Personal Data you provide directly to Third-Party Platforms, Third-Party Websites, or services not operated by us. This includes third-party Product vendors, social media platforms, and ecommerce platforms that may display, market or sell our Products.

We may collect the following Personal Data:

5.1. Information you provide to us, such as:
• Name
• Email address
• Phone number
• Billing address
• Shipping address
• Claims, exchanges, returns, and refunds
• Customer Account details
• Payment information (via third-party gateways; not stored by us unless provided outside the Digital Properties)
• Social media user names, profile links, website links
• Support and other correspondence with us
• Survey responses
• Reviews, public posts
• Business registration information (for business accounts)
• Product purchases, and Products you have shown interest in
• Demographic and lifestyle information (for example, if you purchased products that identifies gender, measurements, or use for specific lifestyle activities)

5.2. Information we collect automatically, such as:
• Device identifiers (IMEI/UDID, MAC, IDFA, AAID, etc)
• Operating system
• Browser type and version
• IP address, location
• Referring URLs
• Browsing behaviour, session logs
• Session logs, access dates and times
• Web Cookies, Web Beacons information

5.3. Information from Third-Party Platforms, including:
• Data shared through social media integrations
• Data shared through ecommerce platform integrations
• Payment confirmations
• Fraud-prevention or identity-verification results
• Advertising and user behaviour insights

5.4. Information from Partners:
We may receive information related to you from our Partners, affiliates, ecommerce platforms, data brokers or other third parties, including:
• Delivery, logistics and shipment tracking information
• Transaction confirmations
• Analytics, performance metrics, and reporting data

5.5. Indirectly obtained Personal Data:
We may receive information about you from other sources, independent of you. For example, we may receive information about you as the person designated by another Customer to send a purchased item to your address. We may also receive information related to you from our Partners, affiliates, ecommerce platforms, data brokers or other third parties.

6.1. We use Web Cookies for functionality, authentication, shopping cart operations, analytics, and advertising.

Web Cookies are used to verify, track sessions, and store specific information about the usage of a website, such as the content in the electronic shopping cart. In simple terms, Web Cookies help a website remember information about your visit, which can both make it easier to visit the website again and make the website more useful to you. The Web Cookies data files themselves are entirely anonymous. For more information about cookies, please visit http://www.allaboutcookies.org/.

6.2. We use Web Beacons for analytics, advertising, and performance measurement.

Web beacons are used to track emails, and your journey to and on websites, apps and other Digital Properties. Web Beacons can be used for purposes such as reporting on emails delivery status, web traffic access to and within a website or other Digital Properties, and on advertising endeavours. In simple terms, Web Beacons help to track how you navigate to and on a particular website, which can help a Digital Properties operator identify obstacles to provide a better user experience, and help marketers improve the efficiency of their campaigns. Web beacons do not send information from your digital device back to the company that placed them on the website, app or other Digital Properties you visited. They simply allow operators to collect information about whether and how visitors access an email, website or other Digital Properties. For more information about Web Beacons, please visit https://allaboutcookies.org/what-is-a-web-beacon/.

6.3. You may adjust your browser to block or delete Web Cookies, though functionality of our Digital Properties may be affected, and certain features may not function properly.

You can delete all stored Web Cookies by searching for "cookie" in your computer's file directory and deleting them. Also, you can adjust your settings in your browser to block Cookies. Please note that by doing so you might limit your access to the full functionality of our Digital Properties and others.

6.4. Our Digital Properties may not respond to “Do Not Track” signals. Device-level permission settings may affect collection of location data.

Most current operating systems on mobile devices require that a user give permission for a specific app to collect specific location information—don’t give our app permission if you don’t want that information collected. Mobile devices also often provide users with the ability to adjust settings related to sharing specific location information. Note that adjusting these settings does not completely eliminate the ability of others to develop location information about your device (such as non-specific location information derived from IP addresses).

7.1. Our Digital Properties may contain links to Third-Party Platforms and Third-Party Websites.

7.2. Their privacy practices are outside our control, and our Privacy Policy does not apply to those digital properties.

7.3. You should review their privacy policies before providing Personal Data.

Be sure to review the relevant privacy policy on any digital service you use, and website you visit, to understand how your Personal Data is collected, used, and protected.

We use information about you to meet your expectations, give you a great experience with us, and protect and improve our business in order to better serve you and others in the future. Some examples of this may include:

8.1. To fulfill purchases, including:
• Processing transactions
• Delivering Products
• Managing warranties, returns, exchanges, refunds and claims

8.2. To communicate with you, including:
• Confirming and verifying orders and addresses
• Shipment and tracking information
• Support, inquiries, and claim responses
• Updates to policies, terms, or account information

8.3. To improve our Products and services, including:
• Analysing customer feedback to improve Products
• Planning and managing inventory
• Analysing and predicting future demand
• Auditing processes, employees, manufacturers, suppliers, warehouse operators, logistics providers, and other Partners
• Researching products, markets and competitors

8.4. To maintain and improve our Digital Properties, including:
• Security monitoring
• Analytics, troubleshooting, and performance improvement
• Personalisation of user experience

8.5. To provide marketing (with Consent and opt out option where required), including:
• Sharing Product, Company and Partner’s information
• Announce and share updates about competitions, prizes and prize winners
• Sending promotions or updates
• Displaying targeted advertisements
• Running campaigns or remarketing activities

8.6. To prevent, report and prosecute fraud and security incidents, including:
• Identifying those that pose a threat to you, us, our Digital Properties, visitors, customers, buyers, Partners, and other stakeholders
• Protecting against and responding to malicious, deceptive, fraudulent, or illegal activity
• Preventing and reporting spam activities
• Identifying intellectual property right infringements

8.7. To comply with legal and regulatory obligations, industry standards, and our policies, including:
• Legal and regulatory compliance
• Financial reporting, tax compliance, and financial auditing
• Enforcement of Terms & Conditions and policies

We Process Personal Data only where permitted under Applicable Law based on:
• Consent
• Order and contract fulfilment
• Compliance with legal, statutory and regulatory obligations
• Legitimate interests (e.g. security, analytics, service improvement)
• Protection of safety, rights and prevention of fraud

We do not sell Personal Data. We may combine or share information and Personal Data with:

10.1. Internal stakeholders: We may share such information amongst our current and future companies, subsidiaries, affiliates, officers, directors, employees, and authorised representatives to the extent where their role requires access to the respective information.

10.2. Partners: We may share such information only to the extent necessary with Partners to Perform particular services on our behalf, mainly for:
• Fulfilling orders and delivering Products
• Providing customer care and technical support, including servicing products
• Sending marketing communications and providing advertising services
• Measuring and reporting of advertising frequency, attribution, and performance
• Personalising customer experience on our Digital Properties
• Fulfilling subscription services
• Conducting research and analysis
• Processing payments and refunds, including bank transfers and credit card payments
• Fulfilling and protecting our legal and statutory rights, requirements and obligations
• Conducting audits
• Detecting fraud and other illegal activity
• Maintaining IT infrastructure
• Improving our internal processes, systems and Digital Properties

10.3. Legal and regulatory authorities: Sometimes we may be required to share information and Personal Data for legal reasons, for example, if we are required to do so by a regulation, court order, subpoena or other legal process. We may also share such information when we believe it is necessary to comply with the law or to respond to a government request, or when we believe disclosure is necessary or appropriate to protect us, our Customers, or others.

10.4. Business transfers: We may share such information in the event of a corporate sale, merger, acquisition, joint venture, reorganisation, divestiture, dissolution, liquidation, or similar event.

11.1. Your Personal Data may be stored in Vietnam, and in locations outside of Vietnam.

11.2. Where Personal Data is transferred across borders outside of Vietnam, we implement safeguards required by Applicable Law, including contractual protections and data access protocols.

12.1. Personal Data is retained only for as long as necessary to:
• Fulfill the purposes for which it was collected
• Comply with legal obligations
• Enforce agreements
• Resolve disputes

12.2. Retention periods vary depending on the category of data.

13.1. We employ administrative, technical, and physical safeguards under a risk-based approach to protect Personal Data from unauthorised access, loss, alteration, or destruction.

13.2. Despite these measures, no digital transmission or storage system is entirely secure. As set forth in the applicable Terms of Use or Terms & Conditions for each Digital Property, we cannot and do not guarantee the security of information we collect.

13.3. You also can do your part to help protect the information you provide to us:
• Create a strong and unique password for our Digital Properties. Use that password only on our Digital Properties and not on any other websites or for other accounts.
• Do not share your password with anyone—especially anyone claiming to work with us. We would never contact you and ask for your password—ever.
• Do not record passwords on your digital device, your email or physically. If you must, use a credible password manager program.
• Use secure connections: Avoid public Wi-Fi whilst you log in to our Digital Properties, conduct any purchases, or for any other sensitive activities.
• Secure your home network: Secure your Wi-Fi router with a strong password and consider changing the network name.
• Do not share your Wi-Fi and Internet access with others.
• Set strong passwords to access all your devices.
• Keep your software updated: Regularly update your operating system, browser, and applications to patch security vulnerabilities.
• Use security software: Install and keep antivirus and firewall software active and updated on all your devices.
• Be vigilant about phishing scams, including suspicious emails with links or attachments from unknown senders. Check the sender’s email (our emails always finish with @harara.run), hover over links (our URLs always commence with https://harara.run/), and do not respond to any email or phone request to verify or provide passwords.
• Diligently check your bank and credit card statements, and investigate charges you don’t recognise.
• Be careful what you post and where: Be carful about disclosing personal information about yourself and others online. For example, avoid disclosing your address, date of birth or future whereabouts in social media, online comments and bios. Don’t post pictures of your flight boarding pass, passport or identity cards online.
• Act immediately when you have your phone or computer stolen: Remote lock your device and credit card, if possibly remotely erase your data, change your most important passwords (i.e. email, banking, and social media), contact your service provider to block and replace your SIM, file a police report.
• Report cyber scams and fraud, identity theft, fake websites, scam emails, scam phone calls and other fraudulent activities to the relevant authorities (in Vietnam refer to https://chongluadao.vn/en/posts/info/ – they also provide free legal advise – and internationally refer to https://www.scamadviser.com/articles/how-and-where-to-report-a-scam).

14.1. Our Digital Properties are not intended for Minors under the age of 15.

14.2. We do not knowingly solicit, sell Products or collect Personal Data from Minors without parental consent.

14.3. If you believe we have processed Personal Data of a Minor under the age of 15, or from a Minor without parental consent, contact us immediately.

14.4. If such data is collected unintentionally, we will delete it promptly.

15.1. Subject to Applicable Law, you may have the right to:
• Access Personal Data
• Request correction or deletion
• Object to Processing
• Restrict Processing
• Withdraw Consent
• Request data portability

15.2. Requests may be submitted to: privacy@harara.run

15.3. We may require identity verification before processing any request.

16.1. This Privacy Policy may be translated into languages other than English for convenience purposes only.

16.2. We do not represent or warrant the accuracy, completeness, reliability, or correctness of any translated version of this Privacy Policy.

16.3. In the event of any inconsistency, ambiguity, discrepancy, or conflict between the English version and any translated version of this Privacy Policy, the English version shall prevail and shall be the controlling and legally binding version.

16.4. All interpretation, enforcement, and dispute resolution relating to this Privacy Policy shall be conducted by reference to the English version.

17.1. We operate in Vietnam, but your Personal Data may be stored outside Vietnam.

17.2. We observe and comply with the laws and regulations of the Socialist Republic of Vietnam, without regard to any conflict of laws principles. Upon written request, and as soon as possible and feasible, we shall make reasonable efforts to comply with Applicable Law that deviates from Vietnamese law.

18.1. If any provision of this Privacy Policy is held to be void, invalid, illegal, or unenforceable by a court of competent jurisdiction or under any applicable law, regulation, or rule, that provision shall be deemed severed or modified to the minimum extent necessary to make it valid and enforceable. The remaining provisions of this Privacy Policy shall remain in full force and effect.

19.1. No failure or delay by either Party in exercising any right or remedy under this Privacy Policy shall operate as a waiver of that right or remedy.

19.2. Any waiver of a breach of any provision of this Privacy Policy shall not constitute a waiver of any prior, concurrent, or subsequent breach of the same or any other provision.

20.1. Any Dispute shall first be resolved through good faith informal negotiations between the Parties.

20.2. If the Dispute cannot be resolved through informal negotiations, it shall be finally and exclusively resolved by arbitration administered by the Middle Commercial Arbitration Center (“MCAC”) in Danang City, Vietnam, in accordance with the applicable MCAC Arbitration Rules.

20.3. The arbitration shall be conducted in English, and the arbitral award shall be final and binding.

20.4. Any notice and procedural requirements set out in the Terms & Conditions or this Privacy Policy shall apply to dispute resolution, to the extent not inconsistent with the applicable MCAC Arbitration Rules.

21.1. This Privacy Policy forms part of the Agreement together with the following Site Policies:

(a) Extended Purchase Warranty;
(b) Returns & Exchanges Policy;
(c) Shipping Policy; and
(d) Terms & Conditions

21.2. For the avoidance of doubt, the Site Policies are incorporated into and form part of the Agreement.

21.3. In the event of any inconsistency between this Privacy Policy and the Terms & Conditions, the Terms & Conditions shall prevail to the extent of the inconsistency.

21.4. The Agreement constitutes the entire agreement between the Parties relating to its subject matter of this Privacy Policy, and supersedes all prior or contemporaneous discussions, negotiations, representations, warranties, communications, and understandings, whether oral or written, relating to that subject matter.

22.1. We reserve the right to modify or update this Privacy Policy from time to time.

22.2. If we make material changes to this Privacy Policy, we will provide notice by posting the updated version on the Digital Properties or by other reasonable means.

22.3. We may update the “Last updated” date displayed at the beginning of the Privacy Policy to reflect the date of any modification or update.

22.4. Unless otherwise required by applicable law, material changes to this Privacy Policy will take effect 30 calendar days after notice is provided. Your continued access to or use of the Digital Properties after the effective date of the revised Privacy Policy constitutes your acceptance of the revised terms.

22.5. Notwithstanding the foregoing, changes required for legal compliance, fraud prevention, security, or operational necessity may take effect immediately upon posting where permitted by applicable law.

22.6. If you do not agree to the revised Privacy Policy, you must stop using the Digital Properties before the changes take effect.

23.1. For any inquiries concerning this Privacy Policy or for submitting requests related to your Personal Data, please contact us at:

(a) Email: legal@harara.run

(b) Postal address:
Soyon (Vietnam) Company Limited
Attn: Legal Officer
28 Thanh Luong 20
Hoa Xuan Ward
Danang City, 550000
Vietnam

23.2. You may also contact us to stop receiving communications or to request access, changes, or deletion of your Personal Data.