1. Introduction

Please read this Privacy Policy (“Privacy Policy”) before using our Service including the Website, Widget and API (as defined below), referred to collectively as the “Service”. This Privacy Policy governs the types of information and data we collect and how we use and share this information. Your access to and use of the Service are available for your use only on the condition that you agree to the Terms of Service available under the following address: Link term of services: Link term of services (“Terms of Service”) which include the terms of the Privacy Policy set forth below. LIFESUP Software (“Company”)operates the Service. The address of the Corporation's registered office is MHDI Building, No. 60, Hoang Quoc Viet Street,Cau Giay District, Ha Noi City. We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service.

2. Definitions

API means DxSuite application programming interface to be integrated with the User’s software.

Cookies are small files stored on your Device.

Device means a computer or a mobile device.

Data Controller means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processors (or Service Providers) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject is any living individual who is the subject of Personal Data.

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Service means together the Website, Widget and/or the API (depending on the scope dedicated to a given User).

Usage Data is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

User is the individual using our Service. User corresponds to the Data Subject, who is the subject of Personal Data.

Website means web pages located at dxsuite.io

Widget means a DxSuite widget that may be implemented to the User’s website.

3. The Data Controller

The controller of your Personal Data is: LIFESUP Software, MHDI Building, No. 60, Hoang Quoc Viet Street,Cau Giay District, Ha Noi City.

4. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

5. Types of Data Collected

6. Use of Data

Incentivai Inc. uses the collected Personal Data for various purposes:

• to provide and maintain our Service; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
• to notify you about changes to our Service; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
• to allow you to participate in interactive features of our Service when you choose to do so; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
• to provide customer support; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
• to gather analysis or valuable information so that we can improve our Service; type of Personal Data: email address, first name and last name, Cookies and Usage Data; legitimate interests of the Data Controller;
• to monitor the usage of our Service; type of Personal Data: email address, first name and last name, Cookies and Usage Data; legitimate interests of the Data Controller;
• to detect, prevent and address technical issues; type of Personal Data: email address, first name and last name, Cookies and Usage Data; legitimate interests of the Data Controller;
• to fulfill any other purpose for which you provide it; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
• to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;
• to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information; type of Personal Data: email address, first name and last name, Cookies and Usage Data; upon your consent;
• in any other way we may describe when you provide the information; type of Personal Data: email address, first name and last name, Cookies and Usage Data; necessity for the performance of a contract to which you are a party;

7. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Your Personal Data processed upon your consent will be stored for as long as the relevant consent is not withdrawn and until the expiration of claims resulting from the Service. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

8. Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside Vietnam and choose to provide information to us, please note that we transfer the data, including Personal Data, to Vietnam and process it there. The Company will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information. When we transfer your Personal Data to other countries, we will protect that Personal Data as described in this Privacy Policy and in accordance with applicable law. We use contractual protections for the transfer of Personal Data among various jurisdictions (the Decree on Protection of Personal Data referred to in Article 7. 5).

9. Disclosure of Data

We may disclose Personal Data you provide:

• under certain circumstances, if required to do so by law or in response to valid requests by public authorities;
• if we or our subsidiaries are involved in a merger, acquisition or asset sale;
• to our subsidiaries, affiliates, employees;
• to contractors, service providers, and other third parties we use to support our business;
• to fulfill the purpose for which you provide it;
• for the purpose of including your company’s logo on our Website;
• with your consent in any other cases.

We do not sell or otherwise share your Personal Data, except as described in this Privacy Policy.

10. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. We use appropriate administrative, technical and physical safeguards to protect the Personal Data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use, e.g. we maintain backup copies and only authorized personnel may access the Personal Data.

11. Your Data Protection Rights Under the Decree on Protection of Personal Data (DPPD)

If you are a resident of the Socialist Republic of Vietnam), you have certain data protection rights, covered by DPPD. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. You have the following data protection rights:

• Right to be informed

  The data subject has the right to be informed of his/her personal data processing, unless otherwise provided for by law.

• Right to consent

  The data subject has the right to give consent to the processing of his/her personal data, other than cases specified in Article 17 of this Decree.

• Right to access personal data

  The data subject has the right to access his/her personal data in order to look at, rectify or request rectification of his/her personal data, unless otherwise provided for by law.

• Right to withdraw consent

  The data subject has the right to withdraw his/her consent, unless otherwise provided for by law.

• Right to delete personal data

  The data subject has the right to delete or request deletion of his/her personal data, unless otherwise provided for by law.

• Right to obtain restriction on processing

  • The data subject has the right to obtain restriction on the processing of his/her personal data, unless otherwise provided for by law.
  • Restriction of data processing is carried out within 72 hours after the data subject's request, with all personal data that the data subject requests to be restricted, unless otherwise provided by law.

• Right to obtain personal data

  The data subject has the right to request the Personal Data Controller and the Personal Data Controller-cum-Processor to provide him/her with his/her personal data, unless otherwise provided for by law.

• Right to object to processing

  • The data subject has the right to object to the Personal Data Controller and the Personal Data Controller-cum-Processor processing his/her personal data in order to prevent or restrict the disclosure of personal data or the use of personal data for advertising and marketing purposes, unless otherwise provided for by law.
  • The Personal Data Controller and the Personal Data Controller-cum-Processor shall comply with the data subject’s request within 72 hours after receiving the request, unless otherwise provided for by law.

• Right to file complaints, denunciations and lawsuits

  The data subject has the right to file complaints, denunciations and lawsuits as prescribed by law.

• Right to claim damage

  The data subject has the right to claim damage as prescribed by law when there are violations against regulations on protection of his/her personal data, unless otherwise agreed by parties or unless otherwise prescribed by law.

• Right to self-protection

  The data subject has the right to self-protection according to regulations in the Civil Code, other relevant laws and this Decree, or request competent agencies and organizations to implement civil right protection methods according to regulations in Article 11 of the Civil Code.

If you wish to execute any of the above-mentioned rights, please email us at sales@dxsuite.io. Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.

12. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

13. Analytics

We may use third-party service providers to monitor and analyze the use of our Service and Website.

14. Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processors we work with are:

1. Stripe - Privacy Policy of Stripe Inc. can be viewed at: https://stripe.com/us/privacy.

15. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to thatthird party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

16. Children's Privacy

Our Service does not address anyone under the age of 16 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

17. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating “effective date” at the top of this page, unless another type of notice is required by the applicable law. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you if applicable, you consent to the revised Privacy Policy and practices described in it.

18. Contact Us

If you have any questions about this Privacy Policy, please contact us at sales@dxsuite.io.

19. Privacy Policy Addendum