Privacy Policy

KOVINA NET Privacy Policy Last updated: September 19, 2026 KOVINA NET (“KOVINA”) operates in Vietnam and processes and protects personal data in accordance with Vietnam’s Law No. 91/2025/QH15 on Personal Data Protection, Decree No. 356/2025/ND-CP, and other applicable Vietnamese laws. 1. Scope This Privacy Policy applies to users who visit the KOVINA website or provide personal data through equipment purchase or rental inquiries, contact requests, excavator operator job registration, or other website functions. 2. Personal data we may process A. Equipment purchase, rental and general inquiries - Name - Company or affiliation, if provided - Phone number - Email address, if provided - Zalo, WhatsApp or other messaging contact details - Country or region, if provided - Equipment requirements, specifications and inquiry details - Information required for quotations, contracts, payments, transportation, export or import operations B. Excavator operator job registration - Name - Contact details - Area of residence - Driving or maintenance experience - Qualifications or licenses - Preferred working conditions - Other career information voluntarily submitted by the applicant C. Technical information that may be generated when using the website - IP address - Access date and time - Browser and device information - Access and security logs - Cookie or similar technology information where such technology is used KOVINA generally does not require unnecessary sensitive personal data, such as health, biometric or financial-account data, through ordinary website inquiries. Where sensitive personal data must be processed, KOVINA will identify it as sensitive data and apply the required consent and safeguards under Vietnamese law. 3. Purposes of processing KOVINA may process personal data to: - Respond to equipment purchase, sale and rental inquiries - Check, source and quote used construction equipment available from Korea - Perform contracts, payments, transportation, customs, import and export operations - Communicate with customers and handle their requests - Review excavator operator registrations and future recruitment needs - Operate and secure the website and prevent misuse - Comply with legal obligations and handle disputes KOVINA will not process personal data beyond the notified, consented or legally permitted purposes. 4. Legal grounds and consent KOVINA processes personal data based on valid consent, contract formation or performance, compliance with legal obligations, and other grounds permitted under Vietnamese law. When consent is obtained through the website, KOVINA will provide a clear choice and will not use pre-selected consent, misleading consent language or other mechanisms that improperly interfere with a user’s choice. Where permitted by law, a data subject may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. 5. Disclosure and processors Where necessary for business operations, KOVINA may disclose personal data to or engage: - KONET HOLDINGS and Korean equipment sourcing, inspection and export partners - Carriers, freight forwarders, shipping lines, customs and logistics providers - Payment, accounting, legal and professional service providers - Website hosting, server, email, security and IT service providers - Competent government authorities where required by law KOVINA applies contractual or documented requirements on purpose, scope, security and responsibility where required by applicable law. 6. Cross-border transfers, including to the Republic of Korea For equipment inspection, sourcing, quotations, contracts, export and logistics operations, KOVINA may transfer necessary personal data to KONET HOLDINGS or relevant partners in the Republic of Korea. Personal data may also be stored or processed outside Vietnam where hosting, cloud, email or other IT infrastructure is located overseas. Where a cross-border transfer occurs, KOVINA will implement the safeguards required by Vietnam’s Personal Data Protection Law and Decree No. 356/2025/ND-CP and, where legally required, prepare, retain and submit the applicable cross-border transfer impact assessment dossier. 7. Retention and deletion KOVINA retains personal data only for as long as reasonably necessary for the processing purpose. - General inquiries: retained for a reasonable period after consultation and follow-up are completed, then deleted or destroyed. - Contract, transaction, payment, import and export records: may be retained for periods required by contract, accounting, tax, commercial or other applicable laws. - Job applicant data: information of unsuccessful applicants will be deleted or destroyed after the recruitment purpose ends, unless the applicant separately agrees to retention for a future candidate pool. - Legal disputes or obligations: information may be retained as necessary until the relevant obligation or dispute is resolved. When the retention purpose and period expire, KOVINA will securely delete or destroy personal data so that it cannot be reasonably restored. 8. Data subject rights Subject to Vietnamese law, data subjects may have the right to: - Be informed about processing of their personal data - Consent to or refuse processing - Withdraw consent - Access or receive their personal data - Request correction or supplementation - Request deletion or restriction of processing - Request measures to protect their personal data - Lodge complaints, report violations, initiate legal proceedings or claim damages as permitted by law Requests may be submitted through the website inquiry form or the official phone, Zalo or WhatsApp channels shown on the KOVINA contact page. KOVINA will verify the requester’s identity and handle requests within the period required by law. 9. Children’s personal data KOVINA’s website and equipment-related services are generally intended for adults. Where KOVINA must process a child’s personal data, KOVINA will obtain the consent required under Vietnamese law from the legal representative and, where required, the child, while prioritizing the child’s rights and interests. 10. Security measures KOVINA applies reasonable administrative, technical and physical measures to prevent loss, leakage, unauthorized access, alteration or misuse, including: - Restricting access to personal data - Managing administrator accounts and permissions - Applying transmission and storage safeguards where appropriate - Managing server, hosting and security logs - Backup and recovery procedures - Managing responsibilities of personnel handling personal data - Periodic review and improvement of personal data protection measures 11. Personal data incidents If personal data is leaked, lost or otherwise processed in violation of applicable law, or if such an incident is suspected, KOVINA will take measures to contain the incident, identify the cause, recover systems and prevent recurrence. Where required by law, KOVINA will notify or report the incident to the Vietnamese personal data protection authority and affected data subjects within the applicable statutory period. 12. Privacy contact For questions about personal data processing or to exercise data subject rights, please use: - The KOVINA NET website inquiry form - The phone number published on the KOVINA contact page - The Zalo or WhatsApp contact details published on the website KOVINA will ensure that privacy requests and complaints are reviewed by the appropriate responsible personnel. 13. Changes to this Privacy Policy This Policy may be amended when laws, KOVINA services or processing practices change. Material changes will be announced through the website, and the updated Policy will display its effective or last-updated date. 14. Applicable legal framework This Policy has been prepared primarily with reference to: - Law No. 91/2025/QH15 on Personal Data Protection - Decree No. 356/2025/ND-CP detailing and implementing the Law on Personal Data Protection - Other Vietnamese laws applicable to personal data, data, cybersecurity and related transactions Decree No. 356/2025/ND-CP took effect on January 1, 2026 and replaced Decree No. 13/2023/ND-CP from the same date.