We hope that you can make informed decisions regarding your personal data once you have clearly understood the content presented below. This Privacy Policy explains how Halo Trips Viet Nam, its subsidiaries, affiliates, and jointly controlled entities (collectively referred to as “Halo Trips Viet Nam” or “we”) process your Personal Data. The data processing mentioned herein includes the collection, recording, holding, organizing, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing, erasing, or destroying of Personal Data (collectively referred to as “processing”), carried out on both our website Halotrips.com (“Website”) and the Halo Trips Viet Nam mobile application (“App”).

This Privacy Policy applies to users, applicants, suppliers, vendors, and partners of Halo Trips Viet Nam (“You”).

Please take the time to carefully review this Privacy Policy and contact us if you have any questions.

1. Personal Data Collected

Personal Data means any piece of information about you or through which you can be identified. This includes a single piece of information or a combination of various pieces of information about you – for example, your name, address, date of birth, occupation, phone number, email address, images, bank account and credit card details, gender, or other government-issued identifiers and financial information (“Personal Data”).

As a data controller or data processor (as the case may be), we will collect and process your Personal Data through the methods listed below:

1.1 Data Collection at All Times When You Use the Website/App

  • If you are a User

We collect Personal Data that identifies or is used to identify, contact, or locate a user. Without collecting this Personal Data, we will not be able to fully provide the services on the Website or App as requested by you. Personal Data collected directly by us includes, but is not limited to:

(i) Full name

(ii) Email address

(iii) Phone number

(iv) Date of birth

(v) Gender

(vi) Citizen ID number or Passport number

(vii) Your Booking ID (BID)

(viii) Your booking details (such as hotel name, location, and length of stay)

(ix) Your travel preferences

(x) Your airline loyalty membership details

(xi) Your reviews

 

In certain cases, we may require users to provide government-issued documents as part of our Know Your Customer (KYC) process, which is necessary under applicable laws or our Terms & Conditions to identify you and process requests and/or provide ancillary services to you, such as financial services, refunds, insurance claims, and booking cancellations.

 

  • If you are a Supplier or Vendor

To ensure the Website and its features function to their full potential, we collect Personal Data that identifies or is used to identify, contact, or locate an individual or any property or business associated with the services the Supplier provides on the Website. We will also collect other Personal Data necessary for the fulfillment of all payment obligations between you and us, including all relevant tax obligations.

  • If you use payment and/or transaction services on the Website or App

We will collect certain Personal Data related to the payment and/or transaction services you use. This data includes (but is not limited to) payment card numbers or account identifiers, payment cardholder or account holder information, sender and recipient details, as well as transaction history.

 

  • If you apply for a job at Halo Trips Viet Nam

We will collect your resume/CV, work history, and educational background as part of the application, onboarding, and personnel review/approval process.

1.2. Data From Your Device

Whenever you use the Website, we will collect your Personal Data in the form of technical data regarding your device and device usage, such as information about web pages visited, browsing duration, internet device identifiers (ID), and may include:

  • Geographic Location: We may collect information about your actual location to provide you with relevant offers available at that specific location on the Website. We may also derive your approximate location from your IP address, GPS, and other information provided by your mobile device.
  • Log Files: When you use the Website, we collect information that we refer to as “log files.” Log files may be collected even if you do not create an account on the Website. These log files may include (but are not limited to) your IP address, browser type, operating system, country, pages visited, mobile service provider, device information, and other information related to Internet usage. We use log files to provide you with a better experience when using the Website.
  • Cookies and Similar Technologies: A cookie is a small piece of data stored on your computer or mobile device to help us track your Internet usage. We use cookies in certain notification emails sent to you after each purchase or service booking on the Website. You may disable cookies if you wish to stop this feature; however, please note that if cookies are disabled, you may not be able to access parts or all of the Website, or use some or all of its functionalities.
  • Device Information and Installed Applications: We may collect data and information from your phone and/or from applications installed on your device to provide segmented risk assessment profiles and aggregated statistical information only when strictly necessary, including cases where such information is required for checks related to Halo Trips Viet Nam’s financial services. To protect your identity, we remove all of your personally identifiable information (if any) and assign pseudonyms to those data sets. Any metadata processed in this manner cannot be reconstructed back into the original data previously collected.

1.3. Data Collected from Third Parties

Generally, we collect personal data directly from the data subject; however, in certain exceptional cases, we may collect Personal Data from third parties (“Third Parties”), such as:

  • Companies and/or organizations acting as suppliers and other parties that perform any stage on our behalf, providing services on the Website, our service providers, or parties with whom we collaborate under any contract (or other forms of commitment).
  • Your authorized advisors (including but not limited to accountants, auditors, lawyers, financial advisors, or other professional advisors).
  • Any individual notified by you as your authorized representative.
  • Any individual, government authority, regulatory body, or third party to whom we are permitted or required to disclose data by law.
  • Any Personal Data collected from your employer as part of the service registration on the Website for a business or organization, provided that such registration has been approved by the collective of employees.
  • Personal Data collected in connection with financial information or history when you register, log in, add, and/or link (if applicable) payment cards, loan products, insurance, or other financial products and services or accounts through the Website. This Personal Data includes, but is not limited to, payment card or transaction account history, payment card or account details, and payment mapping and/or payment card or account status or standing from relevant payment or financial service providers or any third party.

In the above cases, data collection will be carried out based on your confirmation/instruction to the relevant Third Party, or depending on whether that Third Party has obtained explicit consent from you prior to such collection.

1.4. Third-Party Data Provided by You

You may provide us with Personal Data related to third-party individuals (including when you add data of any third-party individual, such as flight passengers or hotel guests). In such cases, you represent and warrant to us that you have obtained written consent from the relevant third-party individual, and accordingly, you have the authority to act on their behalf to permit us to collect, use, disclose, and process their Personal Data. Please understand that we will be unable to provide services if the corresponding Personal Data cannot be collected.

2. Methods of Collection, Processing, Usage, or Disclosure of Personal Data

2.1. Use of Personal Data

We may process and use your Personal Data based on your requests and/or the agreements or Terms of Use that you have accepted and agreed to be bound by for the following purposes (“Purposes”), including but not limited to:

  • To identify you as a user or a Provider, including the registration, maintenance, and management of your account on our Website.
  • To provide you with service packages and lifestyle options tailored to your preferences.
  • To verify your account, transactions, and/or registration as we may, in our sole discretion, deem necessary before providing services on the Website if you are a provider, or before providing any of our services if you are a user.
  • To manage, operate, and administer the Website.
  • To contact you regarding your use of and access to the Website, as well as to manage any queries and requests submitted by you through the Website.
  • To customize your experience when you use the Website.
  • To assess and improve customer experience and satisfaction, including managing your loyalty points, providing you with direct or personalized marketing activities, and offering or suggesting services from us, our Providers, or our business partners.
  • To monitor and assess your activities, demographic data, behaviors, search queries, response times for various services provided on the Website, and any Personal Data you have provided to the Website to support and improve the performance, user experience, development, and functions of the Website. We will anonymize your Personal Data (or use other methods as required by applicable laws) before processing your Personal Data for these purposes.
  • To detect and prevent money laundering, terrorist financing, fraud, abusive behavior, and other harmful or illegal acts, including complying with applicable laws, responding to legal requests, and protecting our rights and interests.
  • To publish your reviews regarding the services we provide as well as the products we offer for sale on the Website.
  • To enforce the provisions set forth in the Terms of Use of Halo Trips Viet Nam.
  • To resolve disputes, collect debts, and troubleshoot incidents.
  • For any other purposes that we will specifically notify you of at the time of collecting the Personal Data.

2.2. How we use your Personal Data for marketing activities:

  • For digital marketing, including but not limited to social media, display advertising, Search Engine Optimization (SEO), Search Engine Marketing (SEM), and push notifications, for example: using open graph techniques, etc.
  • Cho các mục đích tiếp thị thông thường bao gồm, nhưng không giới hạn việc gửi cho bạn các email hoặc thông báo về sản phẩm mới, ưu đãi đặc biệt, các sản phẩm của Halo Trips Viet Nam có thể liên quan đến bạn, các bản tin, bản cập nhật, tài liệu quảng cáo, quyền ưu tiên, lời chúc nhân các dịp lễ, phiếu khảo sát và/hoặc thông tin khác mà chúng tôi cho rằng bạn có thể sẽ quan tâm.
  • For your registration, use, and access, as well as the creation of one or more accounts for you on the websites/applications of our subsidiaries and/or affiliates.
  • For the transfer of your reviews on our Website to the websites/applications of our subsidiaries and/or affiliates (“Data Transformation”).
  • We may also notify you of the aforementioned marketing activities through various methods, where applicable (including via SMS, WhatsApp, push notifications, or email).

Please note that you may opt out of receiving marketing information from us, including Data Transformation, by following the unsubscribe instructions provided in our marketing materials or by contacting us using the contact details below so that we can assist with your request. However, please be advised that such opt-out will take effect within 7 (seven) Business Days after your successful unsubscription.

2.3. Legal Basis for Data Processing

We may collect, process, use, or disclose your Personal Data to the extent permitted, on a basis consistent with applicable laws under this Privacy Policy as follows:

  • Consent:

    Generally, we will collect, use, disclose, or process your Personal Data under this Privacy Policy based on your consent when you access the Website and/or make a booking with us.

  • Contract:

    Your Personal Data may be processed to fulfill contractual obligations when you enter into a transaction or make a booking with us, as prescribed in our Terms and Conditions and by this Privacy Policy when using our available services on the Website/Application.

  • Legal Obligation:

    In certain cases, we may process your Personal Data for the purpose of complying with obligations and conditions as prescribed by applicable laws, requests from government authorities, or specialized regulatory bodies.

  • Vital Interests:

    We may process your Personal Data when necessary to protect your vital interests or those of other individuals.

  • Legitimate Interests:

    Personal Data may be processed in accordance with our rights and legitimate interests—for example, to improve service quality, manage security, and prevent fraud—while ensuring that your rights and interests are protected, as presented in this Privacy Policy.

3. Sharing Your Personal Data

We may share your Personal Data with other companies, organizations, and individuals, including our subsidiaries and affiliates, who have agreed to process your Personal Data with a level of security no less than the minimum security standards set forth in this Privacy Policy (each referred to as a “Third Party”) in the course of providing services to you and other customers of Halo Trips Viet Nam, and for any of the following purposes or other purposes consistent with applicable laws:

  • to facilitate bookings or other interactions between users and/or Vendors, if you are a user;
  • to enable us and/or Vendors to perform or provide services/features on the Website, if you are a user;
  • to allow users to request, receive, and complete any booking or reservation requests sent to you, if you are a Vendor;
  • to allow Third Parties to perform verification, authentication, risk assessment, fraud prevention, as well as product development and maintenance that we or other Third Parties deem necessary for you when providing services, including any activities related to anti-money laundering (AML), countering the financing of terrorism (CFT), and credit checks;
    in the event of a merger, consolidation, change of control or ownership, restructuring, and/or sale of corporate assets within Halo Trips Viet Nam’s business operations, your Personal Data may be disclosed and transferred as part of the transaction (even if the transaction is ultimately not consummated);
    in connection with our services, we share Personal Data with providers of website hosting, data analytics, marketing, promotions, credit card transaction processing, credit scoring, and other related services;
  • to support the refund process or insurance claims with Vendors or our service providers, if you are a user; and/or
  • to support the verification process with any third party providing services on our Website, if you are a user.

We will notify you as necessary and seek your consent if we need to collect, use, or further process your Personal Data for purposes other than those specified in this Privacy Policy.

4. Cross-Border Data Transfer

You may use the Services provided through the Website worldwide. To enable this, you acknowledge and agree that your Personal Data may be transferred to or accessed by entities across the globe. Your Personal Data may be transferred from a country where you reside while using our Services (the “Transferring Country”) to other countries (the “Recipient Country”).

When we transfer your Personal Data from the Transferring Country to the Recipient Country, we will comply with all legal and regulatory obligations regarding your data with due care to ensure that your data is protected. Such protection includes requiring a legitimate justification for the cross-border transfer and implementing appropriate measures to maintain a level of protection for your Personal Data that is comparable between countries. Furthermore, we will ensure that the recipient in the Recipient Country is obligated to protect your Personal Data in a manner consistent with the standards under applicable laws. In all cases, we will take appropriate steps to ensure that your Personal Data remains subject to a standard of protection equivalent to the data protection standards prescribed by the laws of your country.

5. Rights Regarding Your Personal Data

In accordance with applicable laws, you may exercise the following rights regarding your Personal Data:

  • Right to be informed and access: You may request information regarding the processing of your Personal Data and receive a copy of the requested information.
  • Accuracy of information: You may create a user account based on the information you provide. By providing such information, registering, and creating an account, you undertake that the information provided is true, accurate, up-to-date, and complete.
  • Right to rectification and erasure: In certain cases, you have the right to request the correction and/or deletion of your Personal Data.
  • Right to restriction of or objection to processing: Under specific circumstances, you may request to restrict or object to the processing of your Personal Data.
  • Right to withdraw consent: You may withdraw your consent to the processing of your Personal Data if such processing is based on your consent.
  • Right to data portability: You may request to receive or transfer your Personal Data to another organization in a machine-readable format, where your data is processed based on your consent or as part of the performance of a contract.
  • Right to lodge a complaint: If your data privacy is violated or if you suffer harm due to the unlawful processing of your Personal Data, you have the right to lodge a complaint with the relevant data protection authority.

You always have the option to choose whether or not to share your Personal Data with us. If you have previously granted consent for data processing and subsequently decide to withdraw that consent, we will respect your decision in accordance with our legal compliance obligations.

However, choosing not to share your Personal Data, withdrawing your consent, or disagreeing with our Privacy Policy may affect our ability to perform necessary actions for the purposes outlined in Section 2, or may restrict your use of the Application or Website.

Please be advised that all requests will be thoroughly screened and verified. To confirm your identity and your authority to make a request, we may require you to provide supporting information or documentation. Once verified, we will process your request within the timeframe prescribed by applicable laws.

6. Amendments & Updates to the Privacy Policy

From time to time, Halo Trips Viet Nam may amend this Privacy Policy to reflect changes in laws and regulations, our operational practices, features on our Website, and/or technological advancements. In the event that such amendments result in changes to the manner in which we collect or use your Personal Data:

  • We will notify you of any such amendments via a general notice posted on the Website or by other means sent to the email address associated with your account;
  • Such amendments will be posted within this Privacy Policy, and the effective date will be noted at the beginning of each respective amended Privacy Policy; and
  • Your continued use of the Website, communication with us, or access to and use of the services following any modifications to this Privacy Policy shall constitute your acceptance of this Privacy Policy and all amendments therein.

Your continued use of Halo Trips Viet Nam’s services, Application, and/or Website after the effective date of any modifications, updates, or amendments to this Privacy Policy—regardless of whether you have reviewed them—shall constitute your agreement to be bound by such amendments.

7. Deletion of Your Personal Data

 

To the extent consistent with applicable laws, you have the right to request that we delete the Personal Data we store from our systems. You may submit a request to us using the contact information below to request data deletion.

We will make reasonable efforts, without undue delay or within the timeframe prescribed by applicable laws, to delete your Personal Data or will make reasonable efforts to remove the means or identifiers by which the Personal Data can be associated with you as an individual, if:

việc lưu trữ Dữ Liệu Cá Nhân đó không còn phục vụ cho mục đích thu thập Dữ Liệu Cá Nhân đó nữa;

  • We are not permitted or required by applicable laws to retain the Personal Data and/or where mandated by applicable laws, based on your request for the deletion of your Personal Data.

Please note that once you request the deletion of your Personal Data, we will no longer be able to provide you with certain services, and you agree that we shall not be liable to you for any loss or damage arising out of or in connection with such termination of services.

8. Retention of Your Personal Data

Unless we delete your Personal Data from our systems upon receiving a request from you, your Personal Data will be retained by us for as long as your account exists, as necessary to provide you with our services, and/or for our legitimate business interests, or for such period as such retention is required or permitted by applicable laws.

We will delete your Personal Data after 5 (five) years, or longer if required by applicable laws and regulations, from the date you terminate or unsubscribe from your account with us.

9. Protection of Your Personal Data

We will protect your Personal Data by maintaining reasonable security arrangements, including physical, technical, and organizational measures, to prevent unauthorized access, collection, use, disclosure, copying, modification, processing, or similar risks. However, please be especially advised that although we implement various security measures to protect your information, nothing on the internet is 100% secure, and we cannot guarantee the absolute safety of your Personal Data.

If we encounter a data breach involving your Personal Data, to the extent required by applicable laws, we will notify you through our channels, whether directly or indirectly, to provide you with sufficient information regarding such data breach and will exert our best efforts to protect your Personal Data from misuse.

10. Links to Other Websites

The Website may contain links to other websites. However, we do not have any control over such linked websites. Please be aware that we shall not be responsible for the privacy policies or privacy practices of those websites, and we recommend that you carefully read the privacy policy of each website you visit that collects your Personal Data.

11. Complaints

If you have a complaint regarding our processing of your Personal Data, please contact us using the Contact Information provided below. We will handle your complaint confidentially. We will contact you within a reasonable timeframe after receiving your complaint to discuss the matter and present options for resolving your complaint.

If there are any complaints regarding the processing of your Personal Data that we are unable to resolve, you may lodge a complaint with the relevant competent regulatory authority. Any Personal Data we collect while processing or resolving your complaint will be used solely for the purpose of resolving such complaint.

12. Contact Information

If you have any questions or complaints regarding this Privacy Policy, or if you wish to access and/or correct your Personal Data, please contact the relevant Data Protection Officer (DPO) in your country:

  • Halo Trips Viet Nam DPO and Compliance Team

    Email: contact@halotrips.com
    Address: 3A Building, Resco Residential Area, Che Lan Vien Street, Co Nhue 2 Ward, Bac Tu Liem District, Hanoi, Vietnam.Halo Trips Viet Nam

13. Language & Interpretation

This Privacy Policy may be translated into multiple languages. In the event of any conflict or inconsistency between the English version of this Privacy Policy and any translated versions in other languages, the English version shall prevail.

Any capitalized terms not defined herein shall have the same meaning as set forth in Halo Trips Viet Nam’s Terms and Conditions, as well as in this Privacy Policy.

14. Country-Specific Requirements

Viet Nam

Please note that among the Personal Data we may collect as mentioned above, some may be classified as sensitive personal data under the provisions of Decree No. 13/2023/ND-CP on Personal Data Protection. In such cases, we strongly advise you to carefully review the data you are about to share before proceeding with your transaction with us.

Unless otherwise provided by law, if there is a third-party individual who is a child aged 7 (seven) years or older, you represent and warrant to us that you have obtained the valid written consent of both the child and the child’s parent or legal guardian for our processing of the child’s Personal Data. The Personal Data we collect will include the date of birth to verify age and other information depending on your inquiry or the services you wish to use. We are committed to ensuring that the processing of children’s personal data is always carried out in accordance with the principle of protecting the rights and best interests of children.

15. Privacy Policies in Other Countries

Please check if this Privacy Policy is adapted or translated for your specific country/language. In the event of any conflict or inconsistency between the English version of this Privacy Policy and any translated versions in other languages, the English version shall prevail.