‍Effective from 01/07/2023

‍

I. GENERAL RULES

1. The terms and conditions of the personal data Privacy Policy displayed below (hereinafter referred to as "Privacy Policy " and/or “ Policy ”) set forth the terms and conditions agreed by and between NEO Pay Joint Stock Company (hereinafter referred to as “NeoX”, or “Company” or “We”) and Customer (hereinafter referred to as “Customer”) about, or in connection with, the provision and use of intermediary payment services provided by NeoX (hereinafter referred to as the "Service"). This Policy has the same binding value as a Contract signed between NeoX and Customer with the corresponding terms. By clicking on the registration button and performing the registration procedure or " ‍Effective from 01/07/2023" or similar contents, the Customer confirms that he has read, understood and fully agreed with the terms and conditions. content of the Policy.
2. The policy may be amended, supplemented or updated to suit the company operations from time to time, based on the provisions of Vietnamese law. We advise you to read this policy and regularly check this page to keep up to date with any changes we make. IF CUSTOMER DOES NOT AGREE TO ALLOW NEOX TO COLLECT OR PROCESS YOUR PERSONAL DATA AS DESCRIBED IN THIS POLICY, PLEASE DO NOT ACCESS THE NEOX APPLICATION OR USE THE SERVICES PROVIDED BY NEOX.
3. To the extent of processing personal data under this policy, NeoX is the controller and/or controller and processor of personal data.
4. This Policy applies to Customers who are individuals, organizations and businesses.

II. EXPLANATION OF WORDS

The following words and terms shall have the meanings defined below when used in the Privacy Policy:

1. “NeoX”: is NEO Pay Joint Stock Company, a company duly established and operating under the laws of the Socialist Republic of Vietnam, with Business Registration Certificate No. 0314363533 issued on April 20, 2017
2. “Service”: is service provided by NeoX on the NeoX Application  support Customers, Customers store and perform online payment services for goods, products, and services instead of cash payments, including e-Wallet services and other payment intermediary services developed by NeoX.
3. “NeoX Application” or “Application”: is a software product for Customers on mobile devices or websites to use Services provided by NeoX and/or NeoX's partners, including but not limited to payments from the Customer's card/account/e-wallet, orders for goods and services, look up invoice information.
4. "Personal data": is information in the form of symbols, letters, numbers, images, sounds or similar forms in the electronic environment associated with a specific person or helping to identify a specific person. Personal data includes basic personal data and sensitive personal data in accordance with the provisions set out in this Policy.
5. “Personal data processing”: is one or more activities affecting personal data, such as: collection, recording, analysis, confirmation, storage, editing, disclosure, combination, access, retrieve,  encrypt, decrypt, copy, share, transmit, provide, transfer, delete, destroy personal data or other related actions.

‍

III. TYPES OF CUSTOMER PERSONAL DATA PROCESSED

The type of personal data that NeoX processes will include basic personal data and sensitive personal data.

1. Basic personal data:

Customer's specific information, including: full name; date of birth; sex; place of birth, place of birth registration, permanent residence, temporary residence, current residence, hometown, contact address; nationality; image of the individual; phone number, identity card number, personal identification number, other related documents; marital status; information about individual digital accounts; Personal data reflects activities and history of activities in cyberspace, etc.

2. Sensitive personal data

Data information associated with Customer privacy, including: Political opinions, religious opinions; health status and private life; information related to racial origin and ethnic origin; information about the individual's physical attributes and biological characteristics; information about deposits, information about deposited assets, information about transactions, information about organizations and individuals that are guarantors at credit institutions, bank branches, and intermediary service providers; Other personal data specified by law are special and required necessary security measures, etc.

3. During the time of providing services to the Customer, NeoX may collect and process other personal data of the Customer in accordance with the law.

‍

IV. PURPOSE OF COLLECTING CUSTOMER INFORMATION

NeoX collects and processes personal data provided by Customer to:

1. Provide our products and services to Customers

• Identify, verify and maintain accurate information about the Customer.
• Appraise and approve NeoX's provision of products and services to Customers.
• Consider providing or continuing to provide any NeoX products or services to Customers.

2. Improve and enhance the quality of NeoX's products and services to Customers

• Gain a better understanding of the demand for payment-related services.
• Understand Customers' needs for products and services to improve the quality of NeoX's products and services provided to Customers.
• Specialize and personalize NeoX's products and services to customers.

3. Fulfill obligations in contracts, agreements, terms, conditions and other documents between Customers and NeoX.

• Perform obligations under contracts, agreements to provide products and services of NeoX to Customers.
• Handle or resolve Customer's complaints.
• Communicate and promote NeoX products and services to implement programs and policies or notify Customers of information related to purchase orders or accounts, news, and product/feature updates.
• Monitor, ensure transaction safety, and promptly support Customers in complaints or other emergency situations.

4. Crime prevention, combat and prevention

• Detect, investigate and prevent activities related to anti-money laundering, anti-profiteering or policy violations according to related laws and regulations.

5. Business operations and risk management of NeoX policies

• To ensure NeoX's legitimate business purposes in necessary cases, including but not limited to exchanging information with partners and service providers for NeoX.
• To comply with agreements and contracts between NeoX and other third parties.
• To fulfill reporting, auditing and risk management obligations.

6. Comply with the provisions of Vietnamese law

• Provide to competent State agencies as prescribed by law.
• Perform obligations as prescribed by law and at the request of competent State agencies.

7. In case of processing personal data for purposes other than the above, NeoX will only do so according to the agreement or when receiving consent from the Customer.

‍

V. METHOD FOR CUSTOMERS' PERSONAL DATA COLLECTED AND PROCESSED

1. NeoX and NeoX's data processors, or third parties authorized to process data for NeoX, may apply automatic, manual or other appropriate methods of personal data processing as permitted by law. 
2. When Customers use the NeoX’s Services or access NeoX's website, NeoX can collect information in many different ways so that the Services can operate more effectively and provide better quality of products and services to Customers. The collection of Customer information is done from many diverse sources, including:

• From the data Customers provide when choosing to experience or use products and services on NeoX’s website/app, for example information that Customers provide in account/user registration documents, when participating in surveys, programs, services.
• From the process that NeoX provides services to Customers.
• From verbal and written exchanges and correspondences and communication  between NeoX and Customers.
• From suppliers, service providers, partners and other third parties involved in the operations of NeoX.
• From any available public sources or monitoring devices/tools.
• From competent authorities in Vietnam or abroad.
• From the  analysis of Customer's activities when using the website, including websites, applications or social media platforms.
• From third-party sources with whom the Customer consents to the sharing/providing of personal data, or sources where the collection is required or permitted by law.
• From affiliated third parties providing NeoX’s products or services or referring Customers  to NeoX.
• From Cookies, including: information about Customer's device, browser, browsing habits, etc. to help the better understanding of Customer's preferences, thereby providing better services and improving quality by providing additional features to Customers. By using NeoX's platform, Customers agree that we may use cookies for the purposes set out in this policy.

VI. TIME FRAME FOR CUSTOMER'S PERSONAL DATA PROCESSING

NeoX begins to process Customer's personal data from the time it is provided and  collected  and the process ends when:

• Completing the process of personal data in accordance with the purposes for which it is carried out
• Personal data is deleted according to regulations.
• Applying in accordance with the law or NeoX's policies from time to time.

‍

VII. DISPLAY INFORMATION

When Customers use the Services, NeoX may display a certain amount of Customer information on a separate news page/private news section or in the Customer account information section on the Service system, which though not only that is of a specific Customer, but also of other Customers (whether registered to use the Service or not) can access and refer to it. Customers can customize and choose the information to display or not to display on that particular news page/section. Customers need to consider carefully when deciding what information will be displayed.

‍

VIII. CUSTOMERS' RIGHTS AND OBLIGATIONS RELATED TO PERSONAL DATA PROCESSING

1. Rights of the Customer as a data subject:

• Right to know about the processing of personal data.
• The right to consent or not to the processing of personal data.
• Right of access to view, edit or request correction of the Customer's personal data.
• Right to delete data or request the deletion of Customer's personal data.
• The right to restrict data processing, the restriction of data processing is done within 72 hours after the request of the data owner.
• Right to request NeoX to provide Customer's personal data.
• The right to object to NeoX processing data to prevent or limit the disclosure of personal data or use for advertising, marketing purposes, etc.
• The right to lodge complaints, denunciations and initiate lawsuits according to the provisions of law.
• The right to claim damages when there is a violation of the Customer's personal data protection regulations.
• The right to self-protect according to regulations or request competent agencies and organizations to implement methods to protect civil rights according to regulations.

When there are requests related to the Customer's personal data, NeoX will review the Customer's request to consider and decide to implement it based on legality and validity within the prescribed time period.

‍

2. Customers' obligations to provide personal data for processing in accordance with this Policy:

• Ensure the accuracy of the personal data provided.
• Promptly notify of any changes to the personal data provided; and comply with all applicable requirements for Customer provision of personal data under the law.
• Respect and protect others’ personal data.
• In the event that the Customer provides personal data of other individuals, the Customer must ensure that the Customer has received the consent or valid authorization of that individual before making such provisionto NeoX.

‍

3. How to exercise the right

• Log in to your account, edit or delete Customer information.
• Call the Customer Service line 1900 633864 for assistance in adjusting information or deleting information if there is a basis to determine that the personal information provided by the Customer or requested to be corrected/deleted is correct.
• In addition to exercising the rights to Personal Information that have been established on the above platform, Customers can email a written request to specifically state the request. After receiving the Customer's request, NeoX notifies the Customer to consider the limitations, consequences, and damages that may occur if the Customer's requests are completed before implementing that request. Email to receive requests: cskh@neopay.vn .

‍

IX. SECURITY AND STORAGE OF CUSTOMER DATA

1. We value the safety and security of our Customers' personal data. Therefore, we regularly review and implement many security measures to maintain the safety of personal information, personal data from  any damage of being destroyed, lost, modified.
2. Security measures include:

• Applying a modern electronic security system, encrypting data on NeoX processing systems
• SSL (Secure Sockets Layer) to ensure that Customer's information is fully encrypted and sent over the network.
• Secure PCI or Internet server scanning software proactively protects servers from hackers and other vulnerabilities.
• Provide the use of secure servers. All sensitive information/credits are transmitted via SSL technology and then encrypted into our database, only authorized personnel has special access to the systems and complied to keep the information confidential.
• Ensure access to personal data only granted to authorized personnel.
• Require third party service providers and partners to apply and meet our security requirements and standards and comply with applicable laws.
• Conduct regular checks and assessments on the level of safety and protection of personal information.
• Notify incidents or violations to relevant parties and make efforts to fix and prevent damage within the ability.

‍

3. NeoX will store and retain Customer's personal data for the period of time required by law and this Policy. NeoX will destroy Customer information as soon as it reasonably confirms that: (i) the purpose for which the information was collected is no longer relevant for retaining the data; or (ii) retention is no longer required for any of these legal or business purposes; or (iii) upon the Customer 's lawful and valid request . However, this destroyed information will still be stored and backed up in a third party. Therefore, Customers should consider carefully before uploading information to the system.
4. NeoX is committed to implementing various security measures and always makes every effort to ensure that Customer's personal data is not leaked or disclosed to outside parties. However, NeoX notes that the processing of personal data through electronic systems, the internet and other information technology solutions will not be absolutely confidential and secure. Especially when the Customer's personal data is processed and transmitted to our system or to a third party service provider that the Customer may use.
5. Customers are responsible for ensuring that the personal data is sent securely. Furthermore, it is recommended that Customers take measures to secure their personal data (including information about their accounts and transactions) and not accidentally share or disclose this information to any unauthorized person.

X. SCOPE OF USE OF INFORMATION

1. In order to carry out the above purposes and personal data processing activities, NeoX may share Customer's personal data or personal data of third parties related to Customer to the parties below:

• NeoX employees and authorized employees havingcorresponding functions.
• Service providers, NeoX partners (e.g. banks, other partners, etc.) to process personal data for the purposes specified in this Policy.
• State agencies, competent organizations and individuals are allowed or required  according to regulations and enforce responsibilities.
• To third parties responsible for processing personal data in accordance with the contract, agreement with NeoX.
• Other third parties that NeoX deems necessary to meet and protect the legitimate interests of Customers.
• For credit institutions, payment intermediary service providers.

‍

2. In addition to the above cases, NeoX will not disclose Customer's personal data to any other party unless with Customer's consent.
3. Note, third party websites have separate and own Privacy Policies. It is recommended that Customers read the Privacy Policy of each website to visit. NeoX does not control third party websites or any content contained therein and Customer agrees that NeoX is not responsible for any third-party websites. However, NeoX will seek to protect the integrity of the sites and welcome any feedback on those sites.

XI. TRANSACTION POLICY

1. A transaction on NeoX is the Customer's agreement with the product on the NeoX platform (including product information), with full information of that transaction and the Customer is fully responsible for the decision. use their products and services.
2. In resolving disputes, NeoX creates conditions for the parties to provide necessary evidence and information and resolve them through chat and exchange content. If the parties cannot resolve the matter, they can refer to legal authorities. the law.

‍

XII. OTHER AGREEMENTS

1. NeoX commits to process Customer data based on Customer's consent in accordance with this policy, unless otherwise required by law.
2. In the event that any provision of this Policy is determined to be unlawful or otherwise unenforceable, NeoX will modify such provision, or (in its sole discretion) remove such provision out of this Policy. If any provision of this Policy is determined to be illegal or unenforceable, such determination shall not affect the remaining provisions of this Policy, which shall remain in full force and effect.
3. This Policy will be binding on heirs, personal and legal representatives, successors in title and permitted transferees of customer’s assets (if any). 
4. In case the Customer notices a violation in the processing of the personal data, the Customer has the right to send a written request to NeoX for supports, within NeoX's ability, to prevent or limit data disclosure, unless otherwise provided by law.
5. Customers may send a written withdrawal of their consent to any or all of the contents stated in this policy to NeoX support email: cskh@neopay.vn or via official communication channel(s)available from time to time. If Customer withdraws its consent to data processing in accordance with this policy, NeoX reserves the right to discontinue providing NeoX products or services to Customer and NeoX may need to terminate the existing relationship between the Customer and/or the contract signed. Customer agrees and acknowledges that any withdrawal of Customer's consent to data processing in accordance with this policy will not affect the previous processing of Customer's personal data in accordance with Customer's prior consent..
6. This Privacy Policy is governed and interpreted in accordance with Vietnamese law. If any content of the Privacy Policy is held to be illegal, void or for any reason unenforceable in the reasonable judgment of the Court, or such content shall be deemed severable from the Privacy Policy and shall not affect the validity and enforceability of any remaining provisions of the Privacy Policy. 
7. This Privacy Policy is an integral part of the Terms and Conditions of using the NeoX Service. Customers are responsible for fully and correctly complying with the Terms and Conditions of using the NeoX Service [Link TnC]

NeoX (including the website: https://www.neox.vn/ and applications on mobile, iPad and other platforms) is owned and operated by NeoPay Joint Stock Company (“NeoX”), a company duly established and operating under the laws of the Socialist Republic of Viet Nam, with Enterprise Registration Certificate No. 0314363533 first issued on 20/04/2017.

‍

To respect your privacy, including the information you share when using NeoX’s services, we have carefully set out the contents relating to the collection, processing and use of information (this “Privacy Policy” or “Policy”) within a reasonable framework and for the purpose of developing services that meet your needs.

‍

This Privacy Policy describes how NeoX collects and processes your User Information through NeoX’s websites, devices, products, services, online and offline stores, as well as any applications that refer to this Privacy Policy (collectively, “NeoX Services”).

‍

This Privacy Policy is an important document when you use our Services/Products and is incorporated by reference into the General Terms & Conditions, Service Agreements and other policies of NeoX from time to time.

‍

This Privacy Policy complies with Vietnamese law on personal data protection as promulgated and amended from time to time. 

‍

“User” or “you” means any individual, organization or enterprise that connects to and/or uses any NeoX Products/Services.

“Personal Data” or “information” means information in the form of symbols, letters, numbers, images, sounds or similar forms in an electronic environment associated with you or helping to identify and/or uniquely distinguish you when you use any NeoX Products/Services. Personal Data includes basic personal data and sensitive personal data as prescribed by law.

‍

“Data Processing” means one or more activities that impact Personal Data, such as: collection, recording, analysis, verification, storage, modification, disclosure, combination, access, retrieval, recovery, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction of Personal Data or any other related actions. 

‍

1. Consent:

Unless otherwise provided by law, you will be notified by us about the processing activities related to your Personal Data.

By confirming your consent and using any NeoX Products/Services, we understand that you agree with the practices described in this Privacy Policy. This is a fundamental principle when you use NeoX’s services and when we approach privacy and User Information at NeoX.

‍

If you do not agree with this Privacy Policy, you should stop providing any User Information to us and/or exercise your rights as set out in Section 8 below.

‍

We reserve the right to amend and supplement this Privacy Policy at any time in order to improve it. We encourage you to review this Privacy Policy regularly to obtain the latest updates and ensure that you are aware of and can exercise control over your information.

‍

2. Purposes of Information Collection:

We use your User Information to operate, provide, develop and improve the products and services we offer to you. These purposes include

‍

2.1. Order placement, delivery and provision of products and services:

We use your personal/organizational information to receive and process the provision of our Products/Services, including but not limited to E-Wallet Services, Payment Gateway Services and other related Products/Services. We also use such information to contact you regarding the provision and use of Products/Services, as well as promotions, advertising and other utilities on NeoX

‍

2.2. Provision, troubleshooting and improvement of NeoX Services:

We use your information to provide the existing functions, features, products and services; and to support performance analytics, bug fixing, as well as to improve and upgrade usability and effectiveness of NeoX Services so as to meet your payment, linking, usage and experience needs on NeoX from time to time.

‍

2.3. Service recommendations:

We use your information to recommend features, products and services that you may be interested in, determine your preferences and enhance your experience with NeoX Services from time to time

‍

2.4. Provision of voice, image and camera services.

When you use our voice, image and camera services (if any), we use your voice input, images, videos and other information to respond to your requests, provide the requested services and improve our services.

‍

2.5. Compliance with legal obligations

In certain circumstances, we collect and use your information to ensure compliance with the law. For example, we collect information about you from merchants, service providers, partners and other third parties in order to verify identity and serve other purposes relating to the provision of NeoX services.

‍

2.6. Communication with you:

We use your information to contact you regarding NeoX Services via various channels (e.g. telephone, email, chat, etc.).

‍

2.7. Advertising

We use your information to display interest-based advertisements for features, products and services that you may be interested in. We do not use your directly identifiable information to display interest-based advertising; we may apply analytical tools to support the promotion of our products and services

‍

2.8. Security

We use User Information to prevent and detect fraud and abuse, to protect the security of our customers, and to prevent activities that attempt to access, damage or destroy customer accounts or impersonate NeoX customers and others. We may also use scoring or similar methods to assess and manage credit risk.

‍

2.9. Other purposes

Depending on our business situation and as permitted by law, we may collect, store and provide information at the request of NeoX or competent state authorities.

‍

3. Scope of Collection:

We collect your information to provide and continuously improve our products and services. The types of User Information that we collect include:

‍

3.1. Information you provide to us

We receive and store any information you provide during your use of NeoX Services, including:

Creation or update of a NeoX service account. Depending on the Products/Services used by Users/Partners, the information may include but is not limited to:

‍

3.2. For individuals:

If the individual is a Vietnamese citizen: full name; date of birth; nationality; phone number; email; citizen identification number or identity card number or valid passport number, date of issue, place of issue.

If the individual is a foreigner: full name; date of birth; nationality; phone number; valid passport number, date of issue, place of issue, entry visa (if any).

‍

3.3. For organizations:

Name, email, phone number, username, Enterprise Registration Certificate number, type of business, information on legal representative, bank account information, business address, etc. of the User.

The User warrants that all information provided to NeoX is accurate and shall be fully responsible before the law for such information.

‍

The User may choose not to provide certain information; however, in such cases you may not be able to take full advantage of our services.

‍

We automatically collect and store certain types of information about your use of NeoX Services/Products, including information about your interactions with content and services available through NeoX Services/Products.

‍

3.4. Cookies:

Like many other websites and platforms, we use “cookies” to collect and analyze IP addresses used to connect your computer or phone to the Internet; device and connection information such as browser and browser version; operating system; date and time and URLs that lead to our website.

‍

Typically, Users can disable cookies in accordance with the Cookie Policy, under which you will still be notified by us about the use of Cookies before or during your access to or use of NeoX Products/Services.

‍

3.5. Google Analytics:

We may collect User Information via Google Analytics – a tool that records data on the number of visits to certain sections or Products/Services introduced by NeoX, as well as the level of User interest in such Products/Services. We use these metrics to monitor and improve our operations to facilitate your use of our Products/Services.

‍

From time to time, we may refuse to provide Products/Services if there are any suspicions or warnings of violation of our security regulations.

‍

We may receive information about you from other sources, such as updated address and delivery information from our service providers or any sources from which we lawfully collect information.

‍

We use such information to correct, update, upgrade and develop Products/Services and for other purposes under this Privacy Policy or relevant regulations.

‍

4. Retention Period:

We will retain Personal Data in accordance with the regulations on protection of personal information confidentiality and/or other applicable laws. We will delete or remove identifiers from your Personal Data when we receive a request from you that complies with applicable law, or when we have reasonable grounds to determine that: (i) the retention of such Personal Data no longer serves the purposes for which it was collected; (ii) retention is no longer necessary for any lawful or business purpose; and (iii) there are no other legitimate interests requiring further retention of such Personal Data.

‍

We reserve the right to refuse to delete or destroy data where your request is inconsistent with the current personal data protection regulations, or although consistent, falls into cases where we are not allowed to delete or destroy data under such regulations.

‍

5. Information Sharing

User Information is an important part of our business, and we do not use User Information for sale or purchase with third parties.

‍

We only share User Information as described below and with NeoX’s subsidiaries, affiliates, member companies, branches and other partners, including:

‍

5.1. Transactions involving third parties:

We may provide you with services, products, applications or features provided by third parties for use on or through NeoX Services.

‍

We may also provide affiliate services from partners, clients and other products on NeoX’s platform.

You will be able to know when a third party is involved in your transactions, and we share User Information related to such transactions with that third party.

‍

5.2. Service providers:

We may cooperate with other companies and individuals to perform functions on our behalf. For example: through affiliate, integrated or embedded services on e-commerce platforms of individuals or organizations; through bank connections, etc.

These third-party service providers have access to the User Information necessary to perform their functions, but may not use such information for other purposes.

‍

5.3. Business transfers:

As we continue to develop our business, we may transfer, sell or purchase any NeoX business, service or product. In such transactions, User Information is generally one of the business assets transferred but remains subject to the promises made in any pre-existing privacy policy (unless the customer consents otherwise). In certain cases, customer information will of course be one of the assets transferred in the course of any transfer or assignment of business or products/services.

‍

5.4. Protection of NeoX and others:

We may release accounts and User Information when we believe such release is appropriate to comply with the law; enforce or apply our General Terms & Conditions, relevant policies and other agreements; or protect the rights, property or safety of NeoX, our customers or other users. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

‍

Other than as set out above, you will receive notice when information about you may be shared with third parties and you will have the opportunity to choose not to share such information.

‍

6. Transaction Security:

We design our systems with your security and privacy in mind. We work to protect the security of your information during transmission by using encryption protocols and software. In addition, we maintain physical, electronic and procedural safeguards with respect to the collection, storage and disclosure of customer information.

‍

Our security procedures mean that we may request to verify your identity before we disclose User Information to you. Our devices and systems provide security features to protect them from unauthorized access and data loss. You can control these features and configure them to suit your needs.

‍

We recommend that you protect against unauthorized access to your password, computer, devices and applications. We recommend using a unique password for your NeoX account that is not used for other online accounts. Always log out when you finish using a shared computer.

‍

7. Advertising Links:

‍

7.1. Third-party advertisers and links to other websites:

NeoX Services may include third-party advertisements and links to other websites and applications. Third-party advertising partners may collect information about you when you interact with their content, ads and services. For more information about third-party advertising on NeoX, including interest-based advertising, please refer to the relevant notices (if any) from time to time.

‍

7.2. Use of third-party advertising services:

We may provide advertising companies with information that allows them to deliver useful and more relevant NeoX ads to you and to measure their effectiveness. We never share your name or other information that directly identifies you when doing so. Instead, we use advertising identifiers such as cookies or other device identifiers.

‍

8. User Rights:

‍

8.1. Right of access and to be informed:

You may access your information, including name, address, payment preferences, profile information, membership status and User Information on NeoX.

‍

If you have any questions about how we collect and use your information, please contact our customer service department or send information to our contact address directly, by post or by electronic means.

If you do not wish to receive emails or other communications from us, please unsubscribe or follow our instructions given from time to time. If you do not wish to receive in-app notifications from us, please adjust your notification settings in the app or on your device.

‍

Advertising help features on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies or other identifiers, how to have the browser notify you when you receive a new cookie, or how to block cookies altogether. Since cookies and identifiers allow you to take advantage of some essential features of NeoX, we recommend that you keep them enabled. If you want to browse our websites without linking your browsing history to your account, you can do so by logging out of your account and blocking cookies in your browser.

‍

8.2. Right to withdraw consent, request restriction or object to data processing:

You may withdraw your consent, request restriction or object to the collection, processing, use and/or disclosure of your Personal Data that we hold or control by contacting our customer service department or sending information to our contact address directly, by post or by electronic means. However, such withdrawal of consent, request for restriction or objection to processing may mean that we will no longer be able to continue providing Services to you and may need to terminate the existing relationship and/or contract between you and us.

‍

8.3. Right to request provision of data:

You have the right to request us to provide your Personal Data to you by contacting our customer service department or sending information to our contact address directly, by post or by electronic means. You also have the right to request us to provide your Personal Data to other organizations, individuals, or from other organizations, individuals to you, provided that you can provide valid authorization or other documents proving the consent of the data subject as prescribed by law.

‍

Your request will only be considered valid and accepted for processing when it contains all the necessary information and uses the correct form as prescribed by the current personal data protection regulations.

‍

In the event that your request is valid under the law and falls within the cases where we are permitted to provide data, we will notify you through appropriate communication methods about the time, place, form of providing personal data, costs (if any), method, and payment deadline (if any), and we will provide personal data in accordance with this notification and other procedures as prescribed by law.

‍

We reserve the right to refuse to provide your personal data in accordance with the laws on the protection of personal information confidentiality, in cases where such laws require and/or allow an organization to refuse to provide personal data in such circumstances.

‍

8.4. Right to access or rectify Personal Data:

You are also entitled to check, update and adjust your information by logging into your account and editing your information and/or requesting corrections by contacting our customer service department or sending information to our contact address directly, by post or by electronic means.

‍

9. Cross-border Data Transfer

Your information and/or Personal Data may be transferred, stored or processed outside your country for one or more purposes. We will only transfer your Personal Data abroad when and only when we have duly and fully carried out the procedures required by personal data protection laws.

‍

10. Conditions of Use, Notices and Amendments

If you choose to use NeoX Services, your use and any dispute over privacy is subject to this Privacy Policy and our General Terms & Conditions, including limitations on damages, dispute resolution and the application of Vietnamese law. If you have any concerns about privacy at NeoX, please contact us with a detailed description and we will try to resolve it.

‍

Our business changes constantly, and our Privacy Policy will also change. You should check our website frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. However, we stand by the promises we make and will not materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.

‍

11. Commitment to Protect Your Personal Data

Customers’ Personal Data on our platform is committed by the Management Board to be kept absolutely confidential in accordance with the personal information protection policy published on NeoX’s platform. The collection and use of each User’s information shall only be carried out with the User’s consent, except in cases otherwise provided by law and this Policy.

We do not use, transfer, provide or disclose Customers’ Personal Data to any third party without the User’s consent, except in cases provided in this Policy or by law.

‍

In the event that the information storage server is attacked by hackers resulting in loss of Users’ Personal Data, the Management Board shall be responsible for notifying and working with competent authorities for investigation and timely handling, and at the same time informing Users of the incident.

‍

We shall keep absolutely confidential all online transaction information of Users, including digitalized invoices and accounting documents.

‍

12. Related Provisions:

This Privacy Policy is an integral part of and includes the provisions of the General Terms & Conditions and other related policies or any other policies on NeoX.

‍

Receipt and resolution of complaints: When you discover that your information is used beyond the stated purposes or scope, you may send an email or call us to lodge a complaint at the following contacts:

Email : cskh@neopay.vn

Hotline : 1900 633864

‍

To substantiate a complaint, the User must provide sufficient evidence as required.

‍

We are committed to responding immediately or at the latest within 03 (three) working days from the time of receiving the complaint

(Effective Date: 01 September 2024)

‍

ARTICLE 1: GENERAL PRINCIPLES

1.1. Introduction

Welcome to NeoX by NeoPay – a provider of payment intermediary solutions and services (“NeoX”), owned, managed, and operated by Neo Payment Joint Stock Company, a company duly established and operating under the laws of the Socialist Republic of Vietnam, with Enterprise Registration Certificate No. 0314363533, first issued on 20/04/2017, and licensed to provide payment intermediary services under License No. 10/GP-NHNN, issued by the State Bank of Vietnam on 09/05/2022.

‍

The terms “we”, “us”, “Company”, “Platform” or “NeoX” refer to the issuer of the NeoX e-wallet.

The terms “Customer”, “User”, or “Account Holder” refer to any individual or organization that registers, logs in, accesses, or uses the NeoX e-wallet or any service on the NeoX Application.

‍

1.2. Consent

THE TERMS AND CONDITIONS FOR USING THE NEOX E-WALLET SERVICES AND THE PERSONAL DATA PROTECTION POLICY PUBLISHED AT:  (Link PRIVACY PROTECTION POLICY) TOGETHER WITH ANY POLICIES ANNOUNCED ON THE NEOX PLATFORM/SYSTEM FROM TIME TO TIME (collectively, the “General Terms”) govern the rights and obligations of the User as a Customer when using the NeoX e-wallet services provided on the NeoX Application.

‍

All terms defined and used herein shall have consistent meaning when referenced in other documents issued by NeoX.

‍

These General Terms constitute an important legal document that Users must carefully read, acknowledge, and fully accept before using the NeoX e-wallet and related services on the NeoX Application.

‍

By registering, logging in, accessing, downloading, or using the NeoX Application, the User confirms that they have read, understood, and agreed to each part and the entirety of the provisions, policies, and terms issued by NeoX from time to time, including but not limited to: these General Terms, the Privacy Policy, service fees, and any subsequent amendments or supplements published by NeoX.

‍

By registering, logging in, or using the NeoX Application, the User acknowledges and agrees to all procedures, requirements, and policies stated in these General Terms. The User hereby consents to NeoX collecting, using, disclosing, and/or processing their personal data as described in these General Terms.

‍

The User is solely responsible for complying with all applicable laws when using NeoX’s products/services, including but not limited to those related to legality of transactions, goods/services, and the origin of funds used for payments.

‍

The User is deemed to have accepted and be bound by these General Terms, and their use of any part of the products or services on the NeoX Application constitutes a legally binding service contract between the User and NeoX.

‍

The User also acknowledges and agrees that NeoX reserves the right to modify, amend, add, or remove any part of these General Terms at any time, in accordance with NeoX’s business policies and applicable laws. Any amendment shall take effect immediately upon publication on NeoX without prior notice. Continued use of NeoX services constitutes the User’s full acceptance of such amendments.

‍

The User affirms that they will read, understand, and agree to all future amendments or supplements (if any) issued by NeoX.

‍

1.3. Recommendation

Users may refuse to use any service on NeoX if they do not agree to any provision under these General Terms.

These Terms are publicly posted on the Platform/System and may be updated periodically.

‍

NeoX recommends that Users regularly review the General Terms to stay informed of any updates or changes.

‍

ARTICLE 2: DEFINITIONS AND INTERPRETATIONS

In these General Terms and Conditions, the following words and expressions shall have the meanings set out below unless the context otherwise requires:

‍

2.1. “NeoX E-Wallet” or “E-Wallet” means the e-wallet product provided by NeoX at the request of the User for the purpose of performing payment transactions and related services on the NeoX Application through the NeoX Account.

‍

2.2. “NeoX Services” include the NeoX E-Wallet service and other utility services provided by NeoX from time to time through the NeoX Application.

‍

2.3. “Account”, “NeoX Account” or “NeoX E-Wallet Account” refers to the electronic identification account (including username and password) issued by NeoX when the User completes the registration process for NeoX Services, including all required identification and verification steps, enabling the User to access, use, manage, monitor, and perform utilities on the NeoX Application in accordance with applicable laws.

‍

2.4. “NeoX Application” refers to the software product for Users on mobile devices or websites to access the E-Wallet and other NeoX Services, including but not limited to payment via the User’s card/account/E-Wallet, top-up, withdrawal, transfer, payments, ordering goods and services, and invoice inquiries.

‍

2.5. “Top-up” refers to the method enabling the User to link and add funds to the E-Wallet Account from their Vietnamese-dong payment account/debit card linked to their E-Wallet.

‍

2.6. “Withdrawal” refers to the method enabling the User to withdraw funds from the E-Wallet Account to the User’s linked payment account/debit card.

‍

2.7. “Transfer” refers to the method enabling the User to transfer funds from their E-Wallet Account to one or multiple other NeoX E-Wallet Accounts.

‍

2.8. “Payment” means the User’s action of using the E-Wallet Application to make lawful payments for goods and services.

‍

2.9. “NeoX Website/System” refers to the website at https://www.neox.vn and other websites or mobile applications owned by NeoX, and/or any other address as notified by NeoX to Users from time to time.

‍

2.10. “Authentication Method” refers to the authentication factors and measures used by NeoX to verify User identity and/or confirm the User’s consent when performing transactions, including but not limited to One-Time Password (OTP), password, biometric data, and other transaction authentication measures approved by NeoX from time to time in accordance with applicable laws.

‍

2.11. “Business Day” means any day from Monday to Friday, excluding Saturdays, Sundays, and public holidays as prescribed by law.

‍

Other terms not defined herein shall be construed and interpreted in accordance with the laws of Vietnam in effect from time to time.

‍

ARTICLE 3: REGISTRATION OF NEOX E-WALLET, ACCOUNT LINKAGE AND USE OF NEOX SERVICES

3.1. Registration of NeoX E-Wallet

a) To use NeoX Services and the NeoX E-Wallet, the User must first ensure that he/she has full legal capacity or has obtained appropriate consent from his/her legal guardian to use NeoX Services as required by law. The User is required to download the NeoX Application, provide all documents required for the NeoX Account Opening Dossier as specified in point (b) below, complete all identification and verification steps, and follow the instructions to register for the NeoX E-Wallet on the NeoX Application.

‍

b) NeoX E-Wallet Account Opening Information and Documents

  i)   For Users who are Vietnamese citizens or individuals without determined nationality:

The dossier includes: full name; date of birth; nationality; occupation, job title; phone number; verified email address; identity documents including personal identification number or passport or citizen identification card, date of issue, place of issue, expiry date; tax identification number (if any); permanent residence address and current residence address (if any); documents proving residency or non-residency status.

‍

  ii)  For Users who are foreign nationals:

Full name; date of birth; nationality; occupation, job title; phone number; verified email address; valid passport or electronic identification information issued by a competent foreign authority, date of issue, place of issue, expiry date; foreigner identification number (if any); visa number or visa-exempt entry documents (for foreign nationals residing in Vietnam, except those exempted by law); registered residence abroad and registered residence in Vietnam (if residing in Vietnam); residency or non-residency status.

‍

  iii) For Users holding two or more nationalities:

Information corresponding to Points (i) and (ii) above; passport information (number, date of issue, place of issue, expiry date); nationality information; residence address in the other country of nationality.

‍

  iv)  For Users being minors or individuals whose NeoX Account is opened through a guardian or legal representative:

The legal representative’s personal information must follow the requirements under Points (i), (ii), and (iii) above.

‍

  v)   For organizational Users:

Founding license, establishment decision or Enterprise Registration Certificate; documents on reorganization, dissolution, bankruptcy or termination of operations (if any); charter of the organization; appointment decision or employment contract for Director/General Director, Chief Accountant or Accounting Manager (if any); documents and data regarding founders, legal representatives, beneficial owners; documents evidencing business activities including business lines, signage photos, company seal samples, headquarters/business location/working space/warehouse photos, and others.

‍

c) The User agrees to provide NeoX with complete, updated and accurate information as required from time to time. The User agrees to promptly notify NeoX of any changes to the NeoX Account Opening Dossier or other information previously provided. The User declares and warrants that the information provided to NeoX is truthful, accurate and takes full responsibility for all information submitted on the NeoX Application.

‍

d) At NeoX’s request, the User agrees and authorizes NeoX to provide and process personal data and organizational data related to the use of NeoX Services for reasonable purposes including but not limited to:

  i)   Assisting NeoX in complying with legal obligations;

‍

  ii)  Reporting to competent State authorities;

‍

 iii) Assessing whether the User has complied, is complying, and will comply with obligations under these General Terms and Conditions.

‍

3.2. Registration for NeoX E-Wallet

a) To use NeoX Services and the NeoX E-Wallet, the User must ensure that he/she has full legal capacity or has obtained the appropriate consent from his/her legal guardian to use NeoX Services as required by law. The User must download the NeoX Application, provide all information and documents required for the NeoX Account Opening Dossier as specified in Section (b) below, complete the identification and verification steps, and follow the instructions to register for the NeoX E-Wallet on the NeoX Application..

‍

b) NeoX E-Wallet Account Opening Information and Documents

  i) For Users who are Vietnamese citizens or individuals whose nationality has not been determined: The dossier includes: full name; date of birth; nationality; occupation, job title; phone number; verified email address; identity document including personal identification number or passport or citizen identification card, date of issue, place of issue, expiry date; tax identification number (if any); permanent residence and current residence address (if any); documents proving residency or non-residency status.

‍

  ii) For Users who are foreign nationals:: Full name; date of birth; nationality; occupation, job title; phone number; verified email address; valid passport or electronic identification information issued by a competent foreign authority, date of issue, place of issue, expiry date; foreigner identification number (if any); visa number or visa-exempt entry document (for foreign nationals residing in Vietnam, except cases exempt by law); registered residence abroad and registered residence in Vietnam (if residing in Vietnam); residency or non-residency status.

‍

  iii) For Users holding two or more nationalities, Information corresponding to Points (i) and (ii) above; passport number, date of issue, place of issue, expiry date; nationality information; residence address in the other country of nationality;

‍

  iv) For Users who register a NeoX Account through a guardian or lawful representative:

The legal representative’s personal information must follow the requirements in Points (i), (ii), and (iii) above

‍

  v) For organizational Users: Founding license, establishment decision or Enterprise Registration Certificate; documents on reorganization, dissolution, bankruptcy, or termination of operations (if any); organization’s charter; appointment decision or employment contract of the Director/General Director, Chief Accountant or Accounting Manager (if any); documents related to founders, legal representatives, beneficial owners; documents evidencing business activities including business lines, signage photos, company seal, headquarters/office/business location/warehouse photos, etc.

‍

c) The User agrees to provide NeoX with complete, updated, and accurate information as required from time to time. The User agrees to promptly notify NeoX of any change related to the NeoX Account Opening Dossier or other information previously provided. The User declares and warrants that all information provided to NeoX is truthful and accurate and takes full responsibility for such information submitted on the NeoX Application.

‍

d) At NeoX’s request, the User agrees and authorizes NeoX to provide and process personal data and organizational data related to the use of NeoX Services for reasonable purposes including but not limited to:

  i)   NeoX in complying with legal obligations;

‍

  ii)  Reporting to competent State authorities;

‍

 iii) Assessing whether the User has complied, is complying, and will comply with obligations under these General Terms and Conditions.

‍

3.3. Linking the NeoX E-Wallet Account with the User’s Payment Account/Debit Card at a Partner Bank

a) The User must complete the linkage between their NeoX E-Wallet Account and their Vietnamese-dong payment account or debit card linked to their Vietnamese-dong payment account opened in the User’s name at a partner bank registered with NeoX, prior to using NeoX Services, and must maintain such linkage throughout the entire period of using NeoX Services.

‍

b) The Vietnamese-dong payment account or debit card used by the User to link with the NeoX E-Wallet Account must have been registered for electronic payment services at the partner bank.

‍

c) The User may link one or multiple Vietnamese-dong payment accounts or debit cards opened in the User’s name at partner banks connected with NeoX

‍

d) The User agrees and authorizes NeoX to send debit/credit instructions to the User’s payment account/debit card at the partner bank when NeoX receives the User’s request for Deposit/Withdrawal/Transfer/Payment.

‍

3.4. Sử Dụng Dịch Vụ NeoXUse of NeoX Services

a) Funds may be loaded (Top-up) into the User’s NeoX E-Wallet Account through the following methods:

  i)   The User’s Vietnamese-dong payment account at a partner bank;

  ii)  A Vietnamese-dong payment account opened at any bank or foreign bank branch in Vietnam;

  iii) Another e-wallet account within the NeoX system or an e-wallet issued by another licensed e-wallet service provider.

‍

b) The User may use their NeoX E-Wallet Account for the following purposes

  i)    Payment for goods, services, fees, and charges for lawful public services available on the NeoX Application;

  ii)   Transfer to another NeoX E-Wallet Account or to an e-wallet issued by another provider outside the NeoX system;

  iii)  Transfer to Vietnamese-dong payment accounts opened at banks or foreign bank branches; and/or

  iv)  Withdraw funds from the NeoX E-Wallet to the User’s Vietnamese-dong payment account at a partner bank.

  v)  Depending on NeoX’s policies from time to time, NeoX may determine and adjust the Service Fee Schedule, transaction fees, fee collection methods, transaction limits, and balance limits applicable to the User’s NeoX Account and/or may upgrade or modify NeoX Services in accordance with law.

‍

NeoX will notify the User through, including but not limited to: the NeoX Website/System, written notices, email to the registered address, SMS, and/or in-app notifications.

‍

c) The User acknowledges that they have full legal capacity and authority to use NeoX Services. The User commits not to use NeoX Services for any purpose related to money laundering, terrorism financing, proliferation financing, fraud, scams, or any other illegal activities.

‍

d) When using NeoX Services, the User is responsible for all actions and errors arising from their use of the NeoX Application and/or execution of transactions.In case of any errors or incidents, the User must immediately contact NeoX via the channels provided on the Application or NeoX Website/System for guidance. NeoX will use reasonable efforts to support the User

‍

e) The User agrees to be solely responsible for managing their Account, NeoX Account Password, authentication information, and access device details. If any such information is lost, stolen, or unlawfully disclosed, the User must promptly update their Account credentials using the tools available within the NeoX Application or notify NeoX Customer Service for temporary account suspension.

‍

ARTICLE 4: TEMPORARY SUSPENSION, FREEZING, AND CLOSURE OF NEOX ACCOUNTS

4.1. Temporary Suspension of NeoX Accounts

a) NeoX shall have the right to temporarily suspend the User’s NeoX E-Wallet Account under any of the following circumstances

  i)     Upon a valid request from the User or the User’s lawful representative;

  ii)    Pursuant to a prior written agreement between the User and NeoX;

  iii)  When there are grounds to suspect that the User’s NeoX Account registration documents contain fraudulent or falsified information, or when the User’s NeoX Account is conducting unauthorized transactions in violation of NeoX’s policies and/or applicable laws;

  iv)  When disputes, inquiries, or complaints arise in relation to the User’s NeoX Account;

  v)   Other cases as specified by NeoX and in accordance with applicable laws from time to time

 vi) The termination of the temporary suspension and the handling of transactions during the suspension period shall be conducted upon the request of the User (or the User’s guardian or lawful representative) or in accordance with agreements between the User and NeoX.

‍

4.2. Freezing of NeoX Accounts

a) NeoX may freeze part or all of the balance in the User’s NeoX E-Wallet Account in the following cases:

  i)  Upon a written decision or request from a competent authority as prescribed by law;

 ii) When NeoX detects errors or mistakes in transactions relating to the account. The frozen amount shall not exceed the amount in error or dispute;

 iii) Other cases as provided in this Agreement or under applicable laws.

b) If the NeoX E-Wallet Account is partially frozen, the unfrozen portion may continue to be used for normal transactions.

‍

c) The lifting of a freeze on a NeoX E-Wallet Account shall only occur once NeoX determines that the circumstances leading to the freeze under Article 4.2(a) have been fully resolved.

‍

d) The User shall be fully responsible for any and all transaction requests arising before NeoX temporarily suspends or freezes the Account. The User acknowledges that NeoX will only apply a temporary suspension upon receiving all required information requested by Customer Service, as reasonably determined by NeoX.

‍

4.3. Closure of the NeoX Account

a) Closure of the NeoX Account means the permanent termination or deletion of the User’s access rights to the NeoX Application. The User will no longer be able to use or reactivate the NeoX Account.

‍

b)  The NeoX Account may be closed in the following cases:

 i)  When it is discovered that the User has used forged or impersonated documents to open or use the E-Wallet for fraudulent, deceptive, or other illegal purposes.

‍

 ii)  The NeoX Account has no transaction activity for a continuous period of 12 months, in accordance with NeoX’s regulations.

‍

 iii)  Upon a valid request from the User, provided that the User has fulfilled all obligations related to the NeoX Account as required by NeoX.

‍

 iv)  The User is an individual who has died, been declared dead, missing, or has lost civil act capacity.

‍

 v)  The User is an organization that has ceased operations in accordance with the law.

‍

 vi) Other cases as permitted by applicable laws.

‍

c) NeoX shall refund to the User or the User’s lawful representative any remaining balance in the NeoX Account immediately prior to the account closure, after the User or the User’s lawful representative has fully provided all required information and documents in accordance with NeoX’s internal regulations.

‍

ARTICLE 5: SUSPENSION, TERMINATION, AND CANCELLATION OF NEOX SERVICES

Beyond the circumstances specified in Article 4 above, the User or NeoX shall have the right to suspend, terminate, or cancel the NeoX Services as follows:

‍

5.1. Suspension, Termination, or Cancellation of Services by NeoX

This refers to NeoX suspending, terminating, or cancelling the provision of products and services on the NeoX Application that NeoX develops or cooperates to provide to Users from time to time.

1. The User agrees, acknowledges, and accepts that any product or service (including the E-Wallet) on the NeoX Application may be suspended, terminated, or cancelled by NeoX for any reason that NeoX deems appropriate and necessary at any time, without requiring the User’s consent. NeoX will promptly notify the User and provide reasonable methods to resolve the User’s rights and benefits (if any) in accordance with NeoX’s decision.
2. The User agrees, acknowledges, and accepts that NeoX may, at any time, suspend or terminate the User’s Account or the User’s access to and use of NeoX Services for any reason NeoX considers appropriate and necessary, including but not limited to cases where the User violates any provision of these Terms and Conditions, or breaches any regulations, policies, or applicable laws related to the use of specific products or services. In addition, NeoX has the right to notify competent State authorities and/or relevant individuals or organizations of such violations by the User.
3. The User further agrees that any grounds for suspension, cancellation, or termination determined by NeoX shall be deemed reasonable. The suspension, termination, or cancellation of NeoX Services may be carried out at any time and under any conditions as solely determined by NeoX.

‍

5.2. User’s Termination of NeoX Services

a) The User may terminate the use of any part of or any specific products/services on the NeoX Application by ceasing to access and use such products/services. Upon the suspension, termination, or cancellation of any part of the products/services, the User agrees that all obligations under this Agreement and any specific terms and conditions applicable to each product/service on the NeoX Application shall remain valid and enforceable.

‍

b) The User is also entitled to contact NeoX through the information published on the Website/System to request termination of any or all NeoX Services or to delete the NeoX Application.

‍

5.3. Legal Consequences of Suspending, Canceling, or Terminating the Use of NeoX Services

a) All applicable terms, conditions, and policies shall remain binding until immediately prior to the User’s suspension, cancellation, or termination of any NeoX Service.

‍

b) Upon cancellation or termination of any Product/Service (or any part thereof), all rights granted to the User under these Terms and Conditions related to such Product/Service shall immediately cease. The User must promptly settle all outstanding fees, charges, and any other amounts due and payable to NeoX in connection with the terminated Product/Service (if any).

‍

c) In the event that all Products/Services have been terminated, the User hereby irrevocably and unconditionally authorizes NeoX to refund any remaining balance in the User’s NeoX Account (if any), after deducting all due and outstanding amounts payable to NeoX (including but not limited to fees and charges).

‍

ARTICLE 6: RIGHTS AND OBLIGATIONS OF THE USER

‍

6.1. User’s Rights

a) To use the NeoX Account within the scope permitted by NeoX in accordance with these General Terms, applicable laws and NeoX’s policies as published from time to time (if any).

‍

b) To request NeoX to execute transactions including but not limited to top-up, withdrawal, fund transfer between e-wallets, payment for lawful and valid goods and services, and to be provided with information on payment transactions and the balance of their NeoX Account upon completion of identity authentication and/or transaction confirmation using the Authentication Methods applied by NeoX from time to time and in accordance with applicable laws.

‍

c) To request re-issuance of the Account and other requests relating to the issuance and use of the User’s Account subject to NeoX’s approval; the User shall pay all fees and costs incurred in connection with such approved requests.

‍

d) To be the sole person having full authority to make any requests relating to the use of the Account.

‍

e) To lodge complaints regarding any errors (if any) arising in the course of using the Account and to bear costs in connection with such complaints (if the complaint is incorrect) in accordance with NeoX’s regulations and/or those of relevant organizations, if any. The User may exercise their right to request investigation/complaint handling within 60 days from the date the relevant transaction arises.

‍

f) To register, suspend, terminate, or cancel the use of NeoX Services in accordance with these General Terms.

‍

g) Other rights as may be separately agreed with NeoX and in accordance with applicable laws.

‍

6.2. User’s Obligations

a) To fully provide and be responsible for the accuracy and truthfulness of dossiers, documents, and information as required by NeoX and other competent authorities/organizations in accordance with laws when requesting account opening and during the course of using the Account. To promptly notify NeoX in writing of any changes to information already provided/registered with NeoX.

‍

b) The User shall be responsible for:

(i) Safeguarding devices used to access the E-Wallet;

(ii) Protecting login information, authentication information, and other identification information of the Customer related to the E-Wallet;

(iii) Not providing any Authentication Method information to any third party.

Any request arising from the User’s E-Wallet, including but not limited to User authentication and transaction authentication steps, shall always be deemed as requests made by the User. NeoX shall be exempt from liability for any loss or damage incurred by the User arising from the User’s disclosure of login information, authentication information, and other identification information relating to the E-Wallet. Where the Account information, password is leaked, or suspected of being abused, the User shall immediately take measures to secure the Account, change the password, and lock the Account.

‍

c) The User shall not:

i) Commit any act in violation of these General Terms and applicable laws;

ii) Commit any act infringing NeoX’s intellectual property rights or attacking source code systems, websites, thereby affecting the safety and stability of the NeoX Application, website/System and interests of other Users, or initiating multiple transactions in a short period, distributing malicious software that may harm NeoX’s systems or data.

iii) Provide NeoX with incomplete, untruthful, inaccurate, or non-updated information upon changes;

iv) Use NeoX Services to conduct transactions for the purposes of money laundering, terrorist financing, proliferation financing of weapons of mass destruction, fraud, cheating, giving or receiving bribes, tax evasion, purchase/sale/exchange of virtual currencies, exploiting promotional/advertising programs, and any other acts in violation of laws;

v) Buy, sell, lease, sub-lease, lend, borrow, assign, receive assignment of the NeoX E-Wallet Account and/or otherwise dispose of the Account to another person.

‍

d) The User shall be responsible for safeguarding the Account and for payment of all transactions conducted by them and/or not conducted by them (including transactions not authorized by NeoX) and other transactions where NeoX can provide evidence that the User’s Account has executed such transactions. In case the Account password/information is leaked or another party takes over the Account, the User shall bear all risks and be responsible for payment of all Account transactions, fees, and other financial obligations (if any) executed before the time the Account is locked.

‍

e) The User shall bear full responsibility and any risks (if any) relating to transactions made via the Internet or mobile using the Account, unless such risks arise due to NeoX’s fault. The User shall promptly notify NeoX of any transactions via the Account that the User did not execute and shall cooperate with NeoX in investigating fraudulent transactions arising in connection with the use of the Account.

‍

f) The User shall be responsible for retaining and providing proof of cancellation of recurring payment services in case the User stops using the Account for recurring transactions (monthly, quarterly, etc.).

‍

g) The User shall be responsible for using the Account in accordance with the regulations of laws, the State Bank of Vietnam, NeoX, and/or related merchants/accepting units. The User undertakes not to conduct any illegal transactions, and NeoX shall have the right to refuse processing or refuse payment in such cases.

‍

h) Other obligations as agreed with NeoX and in accordance with applicable laws.

‍

ARTICLE 7: RIGHTS AND OBLIGATIONS OF NEOX

‍

7.1. Rights of NeoX

a) To consider opening a NeoX Account for a user or to suspend, terminate, or cancel the provision of NeoX Services to the User at NeoX’s discretion.

‍

b) NeoX shall not be responsible for the supply of goods/services (including delivery/receipt and the quantity/quality of such goods/services) paid via the Account, regardless of whether the goods/services are delivered/performed or meet quantity/quality requirements. Likewise, NeoX shall not be liable for risks related to online or mobile payment for purchase of goods/services using the User’s Account, except where NeoX is at fault.

‍

c) To request the User to make full and timely payment for Transactions, fees, and other related financial obligations (if any).

‍

d) To request the User to perform authentication methods/re-authentication and to provide, supplement full and accurate information and necessary documentation when requesting issuance of the Account and during Account usage, including information and documents related to Account transactions, in order to verify the accuracy and legality of such transactions.

‍

e) NeoX shall be entitled to reject any complaint from the User relating to transactions with a value of less than VND 200,000 or equivalent, at all types of merchants/accepting units.

‍

f) To set and/or adjust the validity term of the Account from time to time.

‍

g) To refuse authorizing Account transactions and related requests for issuance/use of the Account that are unlawful or invalid under laws, NeoX’s internal rules, State Bank regulations, or the rules of related merchants/accepting units; or where the User fails to complete transaction confirmation via NeoX’s Authentication Methods; or in cases beyond NeoX’s control.

‍

h) To record all conversations with the User via telephone and/or any verbal information between the User and NeoX during the course of Account usage.

‍

i) To lock the Account upon receipt of a notice of information/password leakage or suspicion of abuse.

‍

j) To recover amounts relating to refunded/erroneously credited transactions into the User’s Account due to processing errors, system incidents, transmission failures, or chargeback transactions at merchants previously advanced to the User, and other mistaken transactions where the User fails to prove lawful ownership.

‍

k) Other rights as agreed with the User and in accordance with applicable laws.

‍

7.2. Obligations of NeoX

a) To comply with regulations on issuance and payment of Accounts in accordance with laws and the State Bank of Vietnam; to ensure the User’s rights and keep User information, except where otherwise required by law.

‍

b) To receive requests for investigation/complaints from the User related to Account usage in accordance with the Investigation and Complaint Handling Procedures in Article 12 below.

‍

c) To promptly lock the User’s Account after receiving notice of information/password leakage or suspicion that the Account is being abused, and to notify the Cardholder/User after completion.

‍

d) To list and provide all User transactions arising in a period upon request from the User or competent authorities.

‍

e) Where NeoX, the User, and related parties are unable to agree and/or do not agree with the handling of investigation/complaint requests, dispute resolution shall be conducted in accordance with laws.

‍

f) NeoX shall refund money to the Account Holder in the following cases:

i) NeoX terminates the provision of NeoX Services to the User;

ii) NeoX ceases operation, has its License revoked, is dissolved or bankrupt in accordance with laws;

iii) The User fails to link the Account with a VND payment account or debit card opened at banks in the name of the Account Holder;

iv) Payment of inheritance in accordance with laws where the User is deceased or declared dead;

v) At the request of competent state authorities in accordance with laws;

vi) Cases of closure of the E-Wallet Account and handling of the remaining balance as agreed in writing between the User and NeoX.

‍

g) Other obligations as agreed with the User and in accordance with applicable laws.

‍

ARTICLE 8: DEBITING OF THE ACCOUNT

Cases where NeoX is entitled to debit the NeoX Account:

‍

8.1. To collect amounts due, overdue amounts, fees related to complaints/disputes in accordance with NeoX’s rules and laws, and other legitimate costs arising during management of the NeoX Account and provision of Products/Services.

‍

8.2. To pay other fees in accordance with NeoX’s fee schedule.

‍

8.3. To perform payment obligations at the request of competent state authorities.

‍

8.4. To perform payment obligations under complaint/dispute resolution outcomes where the User is obliged to pay.

‍

8.5. Where an erroneous transfer into the User’s NeoX Account is detected; or where a request to cancel a transfer order/transaction is received from partner organizations providing Services or from customers, due to errors detected against the customer’s payment instructions.

‍

8.6. Other debit cases relating to fraud, scam where there is a conclusion from competent authorities.

‍

8.7. Other cases as prescribed by laws.

‍

ARTICLE 9: INDEMNITY

The User agrees to indemnify NeoX and NeoX’s related parties and hold them harmless from any loss, claim, demand, complaint, proceeding, cost (including but not limited to legal costs), and liabilities that may be incurred by or brought against NeoX and/or NeoX’s officers, employees, etc., arising from or in connection with the User’s use of NeoX Services (or any part of the Products/Services) and/or the User’s breach of these General Terms.

‍

ARTICLE 10: INTELLECTUAL PROPERTY RIGHTS

10.1. All trademarks, logos, service marks, and all other intellectual property rights of any kind (registered or unregistered), including but not limited to content, designs, materials, graphics, software, images, videos, music, sound, software suites, source code, and underlying software related to NeoX (collectively, “Intellectual Property Rights”) are and shall remain the property of NeoX and/or any organizations/agents authorized by NeoX (if any). All Intellectual Property Rights are protected by copyright laws and international conventions. All rights are reserved.

‍

10.2. Except where expressly permitted under these General Terms, the User shall not use, edit, publish, imitate, translate, create derivative works from, distribute, or otherwise use, reuse, copy, modify, or publish any Intellectual Property Rights in any manner without NeoX’s prior written consent. The User shall not assist or enable any third party to use the Intellectual Property Rights in any manner that constitutes infringement of NeoX’s Intellectual Property Rights and/or related rights.

‍

ARTICLE 11: DISCLOSURE OF INFORMATION

11.1. The User agrees that NeoX may collect, store, use, and process information in the NeoX Account Opening Profile as well as other information obtained from the User or third parties for the purpose of customer information verification and/or transaction authentication in accordance with laws. NeoX may also collect, store, use, and process the User’s personal information for research, operational analysis, and improvement of NeoX Services.

‍

11.2. When the User registers a NeoX Account to use NeoX Services, the User understands and agrees to grant NeoX the right to collect, store, use, and process information through access to applications on devices used for login, in accordance with these General Terms.

‍

11.3. The User accepts and grants NeoX an irrevocable and unconditional authorization to disclose or publish information relating to the User or the User’s transactions to individuals or organizations to whom NeoX is required to disclose under any applicable laws or regulations, or pursuant to any request or order from any competent state authority or court.

‍

11.4. The User agrees with NeoX’s Privacy Policy as published on the NeoX Website/System.

‍

ARTICLE 12: INVESTIGATION AND COMPLAINT HANDLING

12.1. Methods of receiving investigation/complaint requests

a) At least two channels shall be applied to receive investigation/complaint information, including via call center (recorded calls, operating 24/7) and at head office/branches, and NeoX shall ensure verification of the basic information previously provided by the Customer.

‍

b) The time limit for the User to request investigation/complaint handling shall be no more than 60 days from the date the transaction subject to investigation/complaint arises.

‍

c) The time limit for handling an investigation/complaint request shall be no more than 45 working days from the date of first receipt of the User’s investigation/complaint request.

‍

d) NeoX shall immediately take measures to temporarily suspend provision of Products/Services when so requested by the User due to suspicion of fraud or loss.

‍

12.2. Handling of investigation/complaint results

a) Within a maximum of 05 working days from the date of notifying the investigation/complaint result to the User, and where the handling time limit under this Agreement has expired but the cause or responsible party has not yet been identified, NeoX shall, within the following 15 working days, agree with the cardholder on a handling plan.

‍

b) Where the User is entitled to a refund, NeoX shall be responsible for refunding the User in accordance with Clause 12.3 below. Where the case shows signs of crime, NeoX shall notify competent state authorities in accordance with criminal procedure laws and report to the State Bank of Vietnam, and concurrently notify the User in writing about the status of handling their investigation/complaint request. Handling of investigation/complaint results shall be under the responsibility of competent authorities. Where competent authorities conclude that there is no criminal element, within 15 working days from the date of receiving the conclusion, NeoX shall agree with the User on a plan for handling the investigation/complaint result.

‍

c) Where NeoX, the User, and relevant parties cannot reach an agreement and/or do not agree with the handling of the investigation/complaint request, dispute resolution shall be carried out in accordance with laws.

‍

d) NeoX shall be responsible for retaining documents relating to the User’s investigation/complaints for the period prescribed from the date the investigation result is accepted by the User.

‍

12.3. Refunds

a) The User shall be refunded directly into their NeoX E-Wallet in the following cases:

i) There is a refund request from the recipient of the funds back to the User’s NeoX E-Wallet;

ii) There is an investigation/complaint request and the investigation/complaint result determines that the User is entitled to a refund. The refund shall be processed by NeoX in cooperation with relevant parties in accordance with regulations.

iii) The Customer’s top-up/withdrawal/transfer/payment transaction on the E-Wallet fails, the Customer’s E-Wallet has been debited but the NeoX Application does not record a successful transaction.

‍

b) NeoX shall not charge any fee for refund processing to the Customer.

‍

ARTICLE 13: SECURITY

13.1. The User undertakes to use the NeoX Application and NeoX Account only for lawful purposes, not to conduct illegal payment or fund transfer transactions, including but not limited to gambling, payment for illegal goods/services, money laundering, and shall immediately notify NeoX of any transaction showing signs of unauthorized use of the User’s NeoX Account and/or NeoX Services known or suspected by the User, or of any known or suspected security breaches, including loss, theft, or unauthorized disclosure of personal information or Account information of the User.

‍

13.2. The User undertakes not to use and not to allow any third party to use the NeoX Application and NeoX Account to perform acts of unauthorized access, system attacks, virus or malware distribution, or other acts in violation of laws, and/or to disrupt or obstruct the normal operation of NeoX’s systems and its partners’ systems, or to interfere with the use of the NeoX Application or NeoX Account by other users.

‍

13.3. The User shall be fully responsible before laws and shall hold NeoX harmless for any use or activities carried out on the User’s NeoX Account. Any fraudulent, deceptive, or illegal activities may serve as grounds for NeoX, at its sole discretion, to suspend the User’s NeoX Account and/or terminate the provision of NeoX Services to the User, and NeoX may report the User’s conduct to competent state authorities for review and handling

‍

ARTICLE 14: LIMITATION OF LIABILITY

14.1. In all cases, NeoX (including but not limited to all of NeoX’s officers and employees, transaction points, and/or NeoX’s related parties) shall not be liable to the User for any loss, damage, liability, or cost under any cause of action arising from the User’s use or inability to use NeoX Services, except where NeoX (including but not limited to all of NeoX’s officers and employees, transaction points, and/or related parties) is at fault in causing such loss or damage.

‍

14.2. However, where NeoX (including but not limited to all of NeoX’s officers and employees, transaction points, and/or related parties) is liable for loss or damage under the above provision, the User agrees that NeoX’s total liability (including but not limited to all of NeoX’s officers and employees, transaction points, and/or related parties) shall be limited to the actual amount of direct damages incurred by the User, and in any event shall not exceed the total amount transferred into and out of the User’s NeoX Account.

‍

14.3. In all circumstances, NeoX shall not be liable for any indirect, special, consequential, or incidental damages arising from or related to the User’s use or inability to use NeoX Services.

‍

14.4. To the extent permitted by laws, the User agrees that NeoX (including but not limited to all of NeoX’s officers and employees, transaction points, and/or related parties) shall not be liable for any loss, damage, liability, and/or cost incurred by the User due to unauthorized access by the User or any third party to NeoX’s servers, interfaces, websites, or to the User’s devices and/or data, whether accidentally or through unlawful or unauthorized means such as hacking or other reasons beyond NeoX’s control.

‍

14.5. NeoX shall not be liable for failure or delay in performing its obligations under these General Terms where such failure or delay results from Force Majeure Events beyond NeoX’s reasonable control. Force Majeure Events are specified in Article 15 of these General Terms.

‍

ARTICLE 15: FORCE MAJEURE EVENTS

15.1. If either Party is affected by any event beyond its reasonable control, including but not limited to fire, explosion, flood or natural disaster; acts or regulations of competent state authorities; war, terrorism, civil unrest; strikes, work stoppage or labor instability; or shortage/interruption of public utility services or carrier services, etc. (collectively, “Force Majeure Events”).

‍

15.2. The Party affected by a Force Majeure Event shall not be liable for obligations under these General Terms to the extent of the impact caused by such Force Majeure Event, provided that the affected Party promptly notifies the other Party in writing of its actual circumstances and makes all reasonable efforts to remove or mitigate the impact of the Force Majeure Event on the performance of these General Terms as soon as reasonably practicable.

‍

15.3. If any Force Majeure Event continues for a period of 30 (thirty) consecutive days, the non-affected Party may terminate these General Terms by sending written notice to the other Party. For the avoidance of doubt, cases where processing systems, transmission systems, or electrical systems malfunction due to incidents, attacks, or for any reasons beyond NeoX’s control and not arising from NeoX’s fault shall also be deemed Force Majeure Events under these General Terms.

‍

ARTICLE 16: CONTACT AND NOTICES

16.1. The User agrees that NeoX or NeoX’s affiliates may send messages or make phone calls to the User via the User’s phone number or send notifications via the NeoX Application in relation to updates on Products/Services and events offered or provided by NeoX or its affiliates. The User agrees that notifications sent via SMS, calls, or in-app notifications under this Article shall not be limited in number or time and shall be fully valid as official notices from NeoX to the User, provided that they comply with applicable laws.

‍

16.2. The User agrees that NeoX has no obligation to periodically notify the User of transaction details conducted by the User.

‍

16.3. All notices and documents (if any) required to be sent to the User by NeoX under these General Terms shall be sent by one of the following methods:

a. By regular mail or registered mail to the latest address of the User as stated in the Account Opening Profile registered with NeoX;

b. By email to the latest email address of the User as recorded by NeoX;

c. By publishing the notice or communication on NeoX’s website;

d. By SMS or phone call to the latest phone number of the User as recorded by NeoX.

‍

16.4. Any notice, document, or correspondence shall be deemed delivered and received if:

a. Sent by regular or registered mail: within 03 (three) working days from the date of dispatch;

b. Sent by the other methods specified in this Article: on the working day following the date of sending such notice or document.

‍

ARTICLE 17: HANDLING OF ERRONEOUS, TECHNICAL ERROR OR SUSPECTED ILLEGAL TRANSACTIONS

17.1. In all cases where the amount of funds credited to the User’s NeoX Account differs from the actual amount requested and topped up by the User, the User shall be obliged to return such difference to NeoX or the remitter in the manner and within the time limit requested.

‍

17.2. Where NeoX has grounds to determine that a transaction has been conducted due to error, technical incident, or has signs of illegality, NeoX may, at its sole discretion, take preventive measures to mitigate possible damages, including but not limited to the following:

a. Ring-fencing or freezing the amount arising from or related to such transaction in the User’s NeoX Account; and/or

b. Temporarily suspending the operation of the User’s NeoX Account; and/or

c. Offsetting or recovering from the User’s NeoX Account the amount arising from or related to such error, technical incident, or illegal act.

‍

17.3. The User agrees that NeoX has the right to take the measures set out in Clause 17.2 above and undertakes to fully cooperate with NeoX in verifying and resolving issues related to erroneous, technically faulty, or suspected illegal transactions. NeoX shall have the right to temporarily lock/freeze the NeoX Account and/or ring-fence/freeze amounts related to the transaction to verify, clarify, and prevent potential damages.

‍

17.4. Where the User fails to cooperate with NeoX or shows signs of misappropriating or dispersing funds arising from or related to errors, technical incidents, or illegal acts, NeoX shall have the right to maintain the preventive measures stipulated in Clause 17.2 and request competent authorities to handle the matter, including criminal handling where there are signs of crime. In all cases, NeoX shall comply with the final conclusions, decisions, or rulings of competent state authorities.

‍

17.5. Where NeoX has grounds to determine that the User has abused NeoX’s promotional programs, preferential policies, or user support schemes, NeoX shall have the right to suspend or terminate such programs/policies/support to one, some, or all related Users and to take necessary measures to recover benefits, support amounts, and economic advantages obtained by such related Users. Where such abuse shows signs of legal violations, NeoX shall notify competent state authorities for handling.

‍

ARTICLE 18: OTHER PROVISIONS

18.1. These General Terms form an integral part of the application dossier for NeoX Products/Services and shall be construed and governed in accordance with Vietnamese laws.

‍

18.2. Any dispute arising from or in connection with these General Terms shall first be settled by amicable negotiation between the Parties. If negotiation fails, the Parties unanimously select the Hanoi International Arbitration Center (“HIAC”) for resolution in accordance with HIAC’s arbitration rules. The Parties agree that the dispute resolution process may use electronic methods on HIAC’s dispute resolution platform. HIAC shall be responsible for ensuring the authenticity of such system.

‍

18.3. NeoX’s failure to exercise or enforce any right or remedy provided under these General Terms or under laws shall not be deemed as a waiver or limitation of such right or remedy, and NeoX reserves the right to exercise such right or remedy at any time NeoX deems appropriate.

‍

18.4. If any provision of these General Terms is determined to be illegal or unenforceable, NeoX shall amend such provision or (at its sole discretion) remove such provision from these General Terms. Any such determination shall not affect the remaining provisions, which shall continue in full force and effect.

‍

18.5. These General Terms shall be binding upon the User’s heirs, personal and legal representatives, successors in title, and permitted assigns (if any).

‍

18.6. The User shall not assign their rights under these General Terms without NeoX’s prior written consent. NeoX may assign its rights under these General Terms without the User’s prior written consent.

‍

18.7. The User acknowledges that NeoX may, under applicable laws and regulations or upon receipt of directives from relevant Government authorities, be required to take certain actions that may be inconsistent with these General Terms. The User agrees not to hold NeoX liable in such cases.

‍

18.8. For disputes arising between the User and any third party, NeoX shall not bear any responsibility and shall only act as a supporter of the User by providing necessary information for the User and such third party to resolve the matter.

‍

18.9. The User and the third party shall directly resolve all issues relating to their transactions. In the event of complaints, disputes, refund requests, etc., NeoX shall have full authority to temporarily hold/freeze relevant funds in the Account until the issue is resolved or a final decision from a competent state authority is issued.