Crown is committed to complying with the Personal Information and Data Protection laws of Vietnam in relation to all personal information it collects. This commitment is demonstrated in this Policy. Personal information held by Crown will be treated in accordance with local Privacy Legislation.
This Policy sets out the broad controls which Crown has adopted to govern the way it collects and uses personal information, the circumstances in which it might disclose personal information to third parties, how persons can access their personal information held by Crown and what they can do if they are unhappy with Crown’s treatment of their personal information.
2. Who is Crown?
In this Policy, “Crown” refers to Crown Equipment (Vietnam) Co., Ltd
This Policy applies to any individuals in respect of whom Crown currently holds, or may in the future collect, personal information.
This Policy applies to personal information. “Personal information” is information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not.
5. What information is not personal information?
Information where Crown has removed any reference to a person, so that the person cannot be reasonably identifiable from the information, is not personal information.
Crown may use this information for its own purposes and commercial gain. For example, the fact that “x” users aged 30-35 have accessed a Crown website is not personal information.
6. How and when does Crown collect personal information?
Crown collects personal information in a variety of ways in the course of conducting its businesses, including:
- in agreements it enters into with customers, suppliers, contractors and other personnel;
- when providing equipment and services and related information to customers, and administering customer accounts;
- when engaging suppliers, contractors and other personnel;
- when responding to questions regarding our products and our business;
- by interacting with people via our websites, email and telephone;
- when conducting trade promotions and competitions; and
- by security video surveillance at Crown sites.
The kinds of personal information collected and held by Crown include (depending on the circumstances) names, addresses and other contact details, details about a person’s work experience and other qualifications, date of birth, driver’s licence details, bank account details, photographs and video footage.
Where reasonable and practicable, Crown will collect personal information directly from the person. Where it may not be clear that this is being done, Crown will seek to identify that this is being done.
However, in some circumstances, it is necessary for Crown to collect personal information through third party service providers or agents (e.g. Crown customer information received from Crown branches) or from a source of publicly available information (e.g. a telephone book).
Personal information collected by Crown may be held in a variety of formats, including hard copy format and on Crown’s computer systems.
If Crown receives personal information that Crown has not requested (unsolicited information) and Crown determines that Crown could not have collected that information under the Australian Privacy Principles if Crown had requested it, then Crown will destroy or de-identify the information if it is lawful and reasonable to do so.
7. How does Crown use personal information?
The use to which we can put personal information depends on the reason for which it was collected. Crown may use personal information for its primary purpose of collection (e.g. to provide our products and services, the delivery of equipment to the person, to process an application for credit) or for any related secondary purpose that we could reasonably be expected to use the personal information for.
In certain circumstances, Crown may use personal information for promotional or direct marketing purposes. However, a person may at any time request Crown not to use their personal information for sending direct marketing material to that person. Such a request can be made by contacting Crown by contacting Crown via our contact details provided under the “Contact Crown” heading below. There is no fee for making such a request.
8. Disclosure of personal information
Crown respects the privacy of personal information and we will take reasonable steps to keep it strictly confidential.
Crown will disclose personal information to third parties if it is necessary for the primary purpose of collecting the information, or for a related secondary purpose, if the disclosure could be reasonably expected (e.g. disclosure to a customer for the purpose of delivering equipment ordered from Crown). Where such a disclosure is necessary, Crown will require that the third party undertake to treat the personal information in accordance with the applicable legislation.
Otherwise, Crown will only disclose personal information to third parties without the consent of the person to whom it relates if the disclosure is:
(a) necessary to protect or enforce Crown’s legal rights or interests or to defend any claims;
(b) necessary to prevent or lessen a serious threat to a person’s health or safety;
(c) required or authorised by law; or
(d) permitted by another exception in local legislation.
Under no circumstances will Crown sell personal information without the consent of the person to whom it relates. It is not likely that Crown will disclose a customer’s personal information to overseas recipients except where required in the direct provision of the nominated goods/services.
9. Information Security
Crown will take all reasonable steps to ensure that all personal information held by Crown is secure from any unauthorised access or disclosure. However, Crown does not guarantee that personal information cannot be accessed by an unauthorised person (e.g. a hacker) or that unauthorised disclosures will not occur.
Crown will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purposes for which Crown is authorised to use it.
10. Accessing personal information
A person may request to access personal information about them held by Crown. Such a request can be made by contacting Crown via our contact details provided under the “Contact Crown” heading below.
Crown will grant a person access to their personal information as soon as possible, subject to the circumstances of the request.
A request to access personal information will be rejected if:
(a) the request is frivolous or vexatious;
(b) providing access would have an unreasonable impact on the privacy of another person;
(c) providing access would pose a serious and imminent threat to the life or health of any person;
(d) providing access would prejudice Crown’s legal rights; or
(e) there are other legal grounds to deny the request.
Crown may charge a fee for reasonable costs incurred in giving access to an individual’s personal information. The fee (if any) will be disclosed prior to it being levied.
11. Correcting personal information
Crown will take reasonable steps to ensure the accuracy and completeness of the personal information we hold. However, if a person believes that any personal information that we hold about them is inaccurate or out of date, then they should contact Crown via our contact details provided under the “Contact Crown” heading below.
Crown deals with complaints via our internal data privacy complaint process, under which a Crown contact officer will be allocated to assess your complaint and respond to you within a reasonable timeframe. Crown takes all complaints seriously and any further action after our initial response to you will vary depending on the nature of your complaint.
13. Additional information regarding Credit Information
The types of credit information that Crown collects and uses for the purpose of assessing an application for commercial credit typically include:
- names, addresses and other contact details of accountholders and guarantors (both prospective and current);
- bank account details;
- driver’s licence details;
- financial information;
- information on the assets held by an individual.
Such information is collected from the relevant individual and from credit reporting bodies, as well as from publicly available information. Crown uses the information collected to create an internal credit assessment report.
Crown discloses credit information to credit reporting bodies:
- to obtain a credit report from the credit reporting body; and
- for the purposes of lodging a default listing against the individual.
When lodging a default listing we may do this ourselves or by our agents.
14. Google Analytics
You may opt out of Google Analytics by using the following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB
Most browsers are initially set to accept Cookies. However, you have the ability to modify the usage of or disable Cookies if you wish, generally through changing your internet software browsing settings.
Note: if Cookies are disabled, it may mean that you experience reduced functionality or you may be prevented from using elements of the Crown website altogether.
15. Contact Crown
Crown Privacy Officer
Factory NX2, Lot S10-S11, Tan Tap-Long Hau Road,
Expanded Long Hau Industrial Park,
Long Hau Commune,
Can Giuoc District,
Long An Province 850000, Vietnam
Telephone: (84) 2 726 255 000