Data Security and Privacy

This Data Security and Privacy Notice (the “Notice”) sets out TCBS’s practices for the processing and protection of personal data at Techcom Securities Joint Stock Company (“TCBS”) in accordance with applicable laws. By using any products, services, utilities and/or by conducting any transaction or establishing any relationship with TCBS in any manner, each organization and individual is required to read, understand, and voluntarily accept and comply with this Notice.

Article 1. Scope of this Notice

This Notice governs TCBS’s collection and processing of personal data of customers who use or interact with TCBS’s products, websites, or services and/or the customer’s related persons whose data must be collected, and/or persons who co-own and/or use TCBS’s products/services in accordance with applicable laws (collectively, “Customers”). TCBS encourages Customers to carefully review this Notice and to regularly check TCBS’s websites for updates and any changes under this Notice.

This Notice forms an integral and inseparable part of the Terms and Conditions for Account Opening and Use of Securities Services at TCBS (attached to the Agreement cum Application for Account Opening and Use of Securities and Open-Ended Fund Certificate Services) (collectively, the “Terms and Conditions”) and/or any other contracts/agreements entered into between the Customer and TCBS (if any).

Article 2. Definitions

2.1. “Personal Data Protection” means activities to prevent, detect, stop, and handle violations relating to personal data in accordance with TCBS’s regulations/policies (as amended from time to time) and applicable laws.

2.2. “Partners” means individuals and organizations that have contracts/agreements with TCBS to provide products or services to Customers to ensure the best Customer experience, including but not limited to: independent individuals or companies; organizations directly or indirectly owned by TCBS; vendors and other partners/organizations.

2.3. “Data Subject” means any individual to whom personal data relates and whose personal data is shared/provided to TCBS and/or TCBS’s Partners.

2.4. “Personal Data” means information in the form of symbols, letters, numbers, images, sounds, or similar forms in an electronic environment that is associated with a specific person or helps identify a specific person. Personal data includes basic personal data and sensitive personal data, as further specified in this Notice.

2.5. “Applicable Laws” means Law on Data No. 60/2024/QH15 passed by the National Assembly on 30 November 2024, Decree No. 13/2023/NĐ-CP on Personal Data Protection issued by the Government on 17 April 2023 (“Decree 13”), and any guiding, amending, supplementing, replacing regulations from time to time; and other relevant laws, decrees, circulars, and legal instruments relating to personal data protection and relevant to TCBS’s operations.

2.6. “Products/Services” means products, services, features, utilities, and systems provided by TCBS under the Terms and Conditions and/or other products/services provided by TCBS or by TCBS’s Partners from time to time.

2.7. “Processing of Personal Data” means one or more operations performed on personal data, including but not limited to: collection, recording, analysis, verification, storage, editing, disclosure, combination, access, retrieval, recovery, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction, or other related actions carried out in accordance with Applicable Laws.

2.8. References to “Data Subject” or “Customer” mean an individual who is concurrently a Data Subject and a Customer of TCBS.

2.9. Any other terms (if any) not defined in this Notice shall be interpreted in accordance with the Terms and Conditions.

Article 3. Categories of Personal Data

3.1. Depending on the type of Products/Services and/or the nature of the relationship between TCBS and the Customer, and the involvement of TCBS’s Partners in personal data processing, TCBS and/or such Partners may collect and/or process one, several, or all categories of the Customer’s personal data, including but not limited to:

3.2. Basic personal data, including but not limited to:

  • Full name (family name, middle name, given name), birth name, and other names/aliases (if any);
  • Date of birth; date of death or missing status (if applicable);
  • Gender;
  • Place of birth; place of birth registration; permanent residence; temporary residence; current address; place of origin; contact address;
  • Nationality;
  • Personal images (including images and information obtained from security camera systems);
  • Telephone number; identity card number; personal identification number; passport number; driver’s license number; vehicle license plate number; personal tax identification number; social insurance number; health insurance card number;
  • Marital status;
  • Information on family relationships (parents, children);
  • Information on an individual’s digital accounts; personal data reflecting activities and activity history in cyberspace;
  • Other information associated with or capable of identifying the Customer that does not fall within sensitive personal data (including digital account information and online activity history, etc.);
  • Other information/data classified as basic personal data under laws in force from time to time.

3.3. Sensitive personal data, including but not limited to:

  • Political opinions; religious beliefs;
  • Health status and private life recorded in medical records (excluding blood group information);
  • Information relating to racial origin, ethnic origin;
  • Information about inherited or acquired genetic characteristics;
  • Information about physical attributes and unique biometric characteristics;
  • Information about sexual life and sexual orientation;
  • Data relating to crime and criminal acts collected and stored by law enforcement authorities;
  • Customer information held by credit institutions, foreign bank branches, payment intermediary service providers, and other licensed entities, including: customer identification information as required by law; account information; deposit information; entrusted asset information; transaction information; information on organizations/individuals acting as security providers at such institutions/entities;
  • Location data determined via geolocation services;
  • Other personal data categorized by law as special and requiring necessary security measures;
  • Other information/data classified as sensitive personal data under laws in force from time to time.

3.4. Website and application-related data, including but not limited to: technical data (including device type, operating system, browser type, browser settings, IP address, language settings, date and time of connection to the website, application usage statistics, application settings, date and time of connection to the application, location data, and other technical communications information); username; password; secure login details; usage data, etc.

3.5. Marketing data, including but not limited to: advertising interests; cookie data; clickstream data; browsing history; responses to direct marketing; and direct marketing opt-out preferences, etc.

Article 4. Collection of Personal Data

4.1. Sources of personal data received by TCBS include, without limitation:

  • Directly from the Customer;
  • From TCBS’s websites: TCBS may collect personal data when the Customer accesses any TCBS website or uses any features/resources available on or through TCBS websites. When the Customer visits a website, TCBS collects information about the Customer’s device and browser (such as device type, operating system, browser type, browser settings, IP address, language settings, date and time of connection and other technical communications information), all or part of which may constitute personal data;
  • From mobile applications: TCBS may collect personal data when the Customer downloads or uses TCBS mobile applications. Such applications may record certain information (including application usage statistics, device type, operating system, application settings, IP address, language settings, date and time of connection, location data, and other technical communications information), all or part of which may constitute personal data. Access to and use of TCBS applications shall be subject to this Notice, any product/service-specific data privacy policy (if any), and TCBS’s internal regulations issued from time to time in compliance with Applicable Laws;
  • From Products/Services: TCBS may collect personal data when the Customer registers for any Products/Services provided via the website or application, logs into the website or application, or transacts in person at TCBS branches/transaction offices;
  • From communications with the Customer: TCBS may collect personal data when the Customer contacts TCBS (in person, by mail, telephone, online, electronic communications, or other means), including through TCBS Customer surveys;
  • From interactions or automated data-collection technologies: TCBS may collect information such as IP address, referring URL, operating system, browser, and other automatically logged connection information, including:
    • cookies, flash cookies, pixel tags, web beacons, or other tracking technologies;
    • cookies, plug-ins, or social media connectors of Partners;
    • any technology capable of tracking personal activity across devices or websites;
    • location information or other metadata provided by a device.
  • Other means: TCBS may collect personal data when the Customer interacts with TCBS through any other channels.

4.2. TCBS may also receive personal data about Customers from third parties, such as:

  • Where the Customer interacts with third-party content or advertisements on a website or in an application, TCBS may receive the Customer’s personal data from the relevant third party in accordance with that third party’s lawful and prevailing privacy policy;
  • Where the Customer elects to make electronic payments directly to TCBS or through TCBS websites/applications, TCBS may receive the Customer’s personal data from third parties (e.g., payment service providers) for such payment purposes;
  • For compliance with obligations under Applicable Laws, TCBS may receive the Customer’s personal data from law enforcement and competent public authorities as prescribed by law;
  • TCBS may receive the Customer’s personal data from public sources (such as phone directories, advertising leaflets, publicly available information on websites, etc.).
  • Whenever TCBS collects personal data from a third party in this manner, TCBS shall ensure that such third party has obtained the Customer’s consent for: (i) the disclosure of the Customer’s personal data to TCBS; and (ii) the processing of such personal data for TCBS’s purposes as stated in this Notice. If the Customer does not agree, the Customer should not provide his/her personal data to such third party.
  • If the Customer is a legal representative or authorized representative of an enterprise/organization working with TCBS under contracts/agreements entered into with TCBS, TCBS may receive the Customer’s personal data from such contracts/agreements. In this case, the enterprise/organization providing the Customer’s information to TCBS (as TCBS’s organizational customer/partner) confirms that it has obtained the Customer’s consent for the provision and processing of such personal data in accordance with this Notice and Applicable Laws.

Article 5. Rights and Obligations of Customers

5.1. TCBS may support Customers in accessing and correcting their personal data upon request in accordance with TCBS’s regulations and Applicable Laws.

5.2. Where a Customer wishes to access his/her personal data, or believes that personal data held by TCBS is inaccurate, incomplete, misleading, or outdated (as applicable), the Customer may submit a request to TCBS via such channels as TCBS may establish from time to time.

5.3. Using reasonable efforts, TCBS will comply with valid and complete requests for access and/or correction upon receipt of the request and any applicable processing fees (if any).

5.4. TCBS may, at its discretion, approve requested corrections and/or require supporting documents evidencing the updated data to prevent fraud and inaccuracies.

5.5. TCBS undertakes to process the Customer’s personal data on the basis of the Customer’s consent for the purposes stated in this Notice, except where consent is not required under Applicable Laws, including:

  • In emergencies where immediate processing is necessary to protect the life or health of the Customer or another person;
  • Disclosure of personal data as required by law;
  • Processing by competent state authorities in situations of national defense and security emergencies, public order and safety emergencies, major disasters, dangerous epidemics; where there is a threat to national security/defense that has not yet reached the threshold for declaring a state of emergency; prevention and suppression of riots, terrorism, crime, and legal violations as prescribed by law;
  • Performance of contractual obligations between the Customer and TCBS or relevant agencies/organizations/individuals as prescribed by law;
  • Serving activities of state authorities as prescribed by specialized laws;
  • Other cases as provided under Applicable Laws.

5.6. Where the Customer identifies any violation in the processing of his/her personal data, the Customer has the right to request TCBS’s assistance, to the extent feasible, to prevent or limit the disclosure of such personal data, unless otherwise provided by law.

5.7. Where the Customer requests to withdraw consent, requests deletion of data, and/or exercises other related rights in respect of any or all of his/her personal data, the Customer may send a request to [email protected]. Depending on the request, TCBS may consider and decide not to process such request and/or to discontinue providing Products/Services to the Customer and/or to terminate other relationships/transactions between the parties where: (i) Applicable Laws and/or competent authorities do not permit TCBS to do so; or (ii) it is not possible to ensure the standards/quality of the Products/Services if such data is deleted/restricted; or (iii) Applicable Laws require TCBS to collect personal data when providing Products/Services; or (iv) in other cases as assessed by TCBS, deletion/restriction may compromise the architecture or infrastructure for protecting historical data and information of the Data Subject.

5.8. Where TCBS decides not to provide/suspend/terminate Products/Services to the Customer, actions taken by the Data Subject under this Article shall be deemed a unilateral termination by the Data Subject of any relationship with TCBS and may result in breach of obligations and/or undertakings under contracts/agreements between the Data Subject and TCBS. In such event, TCBS reserves all lawful rights and remedies. TCBS shall not be liable for any loss suffered by the Data Subject (if any), and TCBS’s lawful rights are expressly reserved with respect to any limitation, restriction, suspension, cancellation, prevention, or prohibition. The Data Subject should note that, due to the nature of TCBS’s operations, Applicable Laws may require TCBS to retain the Data Subject’s information in certain circumstances; accordingly, TCBS may be unable to comply with deletion requests if deletion would result in a violation of law. Withdrawal of consent, requests to restrict processing, deletion requests, or objections to processing shall not affect the lawfulness of any processing carried out prior to such withdrawal/objection based on the Data Subject’s consent.

5.9. For security purposes, the Customer may be required to submit requests in writing or via other methods approved by TCBS from time to time to evidence and authenticate the Data Subject’s identity. TCBS may require identity verification before processing any request.

5.10. Right to update and adjust personal data: Where personal data changes, the Data Subject may access TCBS’s online trading system (if supported) to proactively review and update personal data, or promptly contact and notify TCBS to update such changes. For clarity, the Data Subject bears full responsibility for any delay in updating or notifying TCBS, and such delay shall release TCBS from any losses or risks arising for the Data Subject and related parties (if any).

5.11. Other rights such as complaints, denunciations, litigation, compensation claims, and self-protection shall be exercised in accordance with Applicable Laws, unless otherwise agreed between the Customer and TCBS.

Article 6. Purposes of Processing Personal Data

The Customer acknowledges that providing/sharing complete personal data with TCBS under the Terms and Conditions, this Notice and/or any contracts/agreements entered into with TCBS is necessary to establish and maintain the relationship between TCBS and the Data Subject, including but not limited to the following purposes:

  • Advising on, introducing, and providing Products/Services suitable for the Customer;
  • Developing, improving, and upgrading TCBS Products/Services, features, utilities, and trading systems through reporting, statistics, aggregation, and data analytics (including financial analysis, behavioral analysis, trading trends, preferences, and other factor analyses, etc.);
  • Sending the Customer information relevant to transactions and the Customer’s needs in compliance with Applicable Laws;
  • Notifying the Data Subject of product/service policies, program rules, instructions for using features/utilities, improvements and enhancements to Products/Services, and other information relating to the Data Subject’s rights and obligations which TCBS deems necessary;
  • Displaying website/application/device content and any customization the Customer may select; displaying on TCBS trading platforms/applications separate and integrated information about the Data Subject’s assets, finances, transactions, and contracts; and/or any features/utilities the Data Subject may select to query information and receive reminders to exercise rights and obligations relating to entering into and performing contracts/transactions with TCBS and TCBS’s partners (including where partner-provided products/services/utilities are distributed, delegated, entrusted, or agency-provided by TCBS), and any customization the Customer may choose;
  • Trade promotion activities, including but not limited to: implementing promotions, offers, and customer support programs; managing promotional content/programs, surveys, or other features of websites/apps/devices or survey platforms; online behavioral advertising or needs-/preference-based advertising, and other trade promotion activities related to TCBS Products/Services in compliance with law;
  • Sending communications regarding the Customer’s account administration and features of websites/apps/devices;
  • Verifying identity and ensuring security of the Customer’s personal data in accordance with TCBS know-your-customer processes under Applicable Laws;
  • Protecting against fraud, identity theft, and other unlawful activities;
  • Establishing, exercising, or defending TCBS’s legal rights and claims;
  • Notifying Customers of changes to Products/Services due to changes in state management policies, legal regulations, market conditions, unusual fluctuations, and/or updates to TCBS internal regulations/policies;
  • Providing information at the request of competent state authorities; issuing or coordinating with relevant service providers to issue e-invoices/e-documents and other records in accordance with applicable laws;
  • Anti-money laundering, counter-terrorist financing, sanctions compliance, and reporting to competent authorities as required from time to time;
  • CCTV footage may, in specific circumstances, also be used for: (i) quality assurance; (ii) public security and occupational safety; (iii) detecting and preventing suspicious, inappropriate, or unauthorized use of TCBS utilities/products/services and/or premises; (iv) detecting and preventing criminal acts; and/or (v) investigating incidents at the request of competent state authorities;
  • Verifying professional investor status under securities laws: to best protect Customers’ interests, TCBS may collect, process and/or share Customers’ securities asset data and/or taxable income information with financial institutions, banks, audit firms, or professional investor verification service providers to conduct appraisal procedures as required by law;
  • Providing personal data to TCBS service providers/partners to deliver services, features, and utilities to the Data Subject and/or TCBS;
  • Other purposes, including but not limited to: purposes set out in relevant agreements when the Customer participates in/uses TCBS Products/Services (if any); other purposes relating to TCBS’s governance, management, business, investment, and other activities; and/or any other purpose notified by TCBS to the Customer.
  • Issuing electronic statements upon the Customer’s request to verify the source of funds when the Customer withdraws funds from his/her securities account.

Article 7. Processing of Personal Data

7.1. TCBS undertakes to process Customers’ personal data securely and confidentially and to ensure Customers’ rights in relation to personal data processing in accordance with Applicable Laws.

7.2. TCBS implements appropriate personal data processing methods and suitable technical and organizational security measures to prevent unauthorized access, reading, use, modification, disclosure, destruction, or other unauthorized processing.

However, the internet is not a fully secure environment and TCBS cannot absolutely guarantee that personal data shared over the internet will always remain secure. When transmitting personal data via the internet, Customers should only use secure systems to access websites, applications, or devices. Customers are responsible for keeping their access authentication information secure and confidential for each website, application, or device. Customers must promptly notify TCBS upon discovering misuse of login information and immediately change their access passwords.

7.3. TCBS commits to protecting Customers’ personal data and applies data protection measures, including:

  • Encryption of sensitive data during storage and transmission;
  • Access controls to permit data access only by authorized personnel;
  • Logging and monitoring system access to detect unauthorized access.

7.4. TCBS may commence processing personal data from the time it receives the Customer’s personal data upon the Customer’s consent in the manner prescribed in this Notice. TCBS shall cease processing when the Customer withdraws consent or requests deletion of personal data in accordance with this Notice and Applicable Laws, or upon the occurrence of one or more of the following events (whichever occurs later):

  • The Customer has fulfilled all obligations to TCBS under contracts entered into with TCBS, or has terminated all communications with TCBS;
  • TCBS has completed the processing purposes stated in this Notice.

7.5. Personal Data Processing in certain special circumstances

  • TCBS may record audio/video and process personal data collected from CCTV surveillance in areas where cameras are installed (including but not limited to transaction counters, offices, corridors, exits, etc.) in accordance with security requirements for TCBS’s operations and for the Data Subject as prescribed by law.
  • For the processing of personal data of a missing person or a deceased person (where TCBS becomes aware or is notified), TCBS must obtain consent from the spouse or adult child of such person; if none, consent must be obtained from the parents of such missing/deceased person (except where consent is not required under Applicable Laws).
  • Processing children’s personal data:
    • TCBS respects and protects children’s personal data based on the principle of protecting children’s rights and acting in children’s best interests.
    • In addition to legally required protection measures, before processing children’s personal data, TCBS will verify the child’s age and obtain consent from: (i) the child aged 7 years or older and/or (ii) the child’s parent or legal guardian, as required by law.
    • TCBS will cease processing children’s personal data and irreversibly delete or destroy such data where:
      • Processing is for an improper purpose or the consented processing purposes have been fulfilled, unless otherwise required by law;
      • The child’s parent or guardian withdraws consent, unless otherwise required by law;
      • At the request of competent authorities where there is sufficient basis to determine that the processing adversely affects the lawful rights and interests of the child, unless otherwise required by law.

7.6. Other Personal Data Processing methods: In addition to the processing methods specified in this Notice and Applicable Laws, TCBS may process the Data Subject’s data by other methods, including recording, verification, editing, disclosure, combination, access, retrieval, recovery, decryption, sharing, transmission, provision, destruction, or other related actions in accordance with applicable regulations.

Article 8. Disclosure and Provision of Personal Data

TCBS will not sell, exchange, or lease (for a definite or indefinite term) Customers’ personal data without the Customer’s consent as required by Applicable Laws. TCBS may share, disclose, provide, and/or use Customers’ personal data with the following parties:

  • TCBS employees on a need-to-know basis for the purposes stated in this Notice;
  • External recipients, including other Customers, Partners/subcontractors of Partners, TCBS’s parent companies, subsidiaries, affiliates, and any or all trusted partners having cooperative relationships with TCBS, for the purposes stated in this Notice;
  • Partners with whom TCBS has distribution agreements (where TCBS acts as the Partner’s organizational agent) to provide Products/Services in line with the Customer’s needs;
  • Service providers that support TCBS’s operations, websites/applications/devices, deliver products/services selected by the Customer, or manage activities on behalf of TCBS (e.g., newsletter distribution, surveys, etc.);
  • Where the Customer makes payments via websites/apps or directly to TCBS, the Customer’s personal data may need to be provided to Partners (e.g., payment service providers) to facilitate such payments;
  • In the event of a proposed or completed sale, merger, or transfer of all or part of TCBS’s business or assets (including reorganization, dissolution, liquidation, restructuring, or change of control), TCBS may provide Customers’ personal data to prospective or actual sellers/buyers or their representatives, provided that TCBS has first taken reasonable and lawful steps to ensure the safety and confidentiality of Customers’ personal data;
  • Competent state authorities in accordance with law and/or where permitted by law.

Article 9. Partner Services

9.1. Customers may see advertisements or other content on websites, applications, or devices that may link to the websites or services of TCBS’s partners, advertisers, sponsors, or other Partners.

9.2. TCBS does not control the content or links appearing on Partners’ websites or services and shall not be responsible for the practices employed by such Partner websites or services linked to or from any TCBS website/application/device.

9.3. Access to and use of such websites/services may be subject to the Partner’s own privacy policies and terms of use.

Article 10. Direct Marketing

10.1. As stated in this Notice and in compliance with Applicable Laws, TCBS, its parent companies, subsidiaries, affiliates, direct marketing partners, or service providers may contact Customers by email, SMS, the TCBS mobile application, or other electronic means at any time to provide information regarding products or services that may be of interest to the Customer.

10.2. If the Customer wishes to unsubscribe from such communications, the Customer may select “Unsubscribe” at the footer of the email or send a request to [email protected]. The Customer may also use unsubscribe features provided via TCBS websites and/or applications. If the Customer unsubscribes from marketing/advertising communications, TCBS may still contact the Customer for the purposes of fulfilling the Customer’s instructions, enabling requested transactions/relationships, sending transaction messages, administering the Customer’s account, or as otherwise required or permitted by Applicable Laws.

Article 11. Cookies

11.1. When the Customer uses or accesses TCBS websites, TCBS may place one or more cookies on the Customer’s device. A “cookie” is a small file placed on the Customer’s device when the Customer accesses a website. It records information about the Customer’s device and browser and, in some cases, the Customer’s website preferences and browsing habits. TCBS may use such information to recognize the Customer when returning to TCBS websites, provide personalized services, compile analytics to better understand website operations, and improve TCBS websites. The Customer may use browser settings to delete or block cookies on the device. However, if the Customer chooses not to accept or block cookies from TCBS websites, the Customer may not be able to fully utilize all features of TCBS websites.

11.2. TCBS may process the Customer’s personal data through cookie technology in accordance with this Notice. TCBS may also use retargeting techniques to deliver advertisements to individuals known to have previously visited TCBS websites.

11.3. To the extent Partners embed content on TCBS websites (e.g., social media features), such Partners may collect the Customer’s personal data (e.g., cookie data) if the Customer chooses to interact with that Partner’s content or use that Partner’s services.

Article 12. Data Retention

TCBS will retain Customers’ personal data only to the extent necessary for the purposes stated in this Notice. TCBS may also be required to retain personal data for a period of time as required by Applicable Laws.

Article 13. Acceptance of the Notice

13.1. By signing/confirming the Terms and Conditions or using any Products/Services, website, application, or device, the Customer shall be deemed to have accepted this Notice.

13.2. If the Customer does not accept this Notice or withdraws consent for TCBS to process personal data for the purposes stated herein, such withdrawal may result in TCBS’s provision of products/services and features on TCBS websites/applications/devices being limited, restricted, suspended, cancelled, prevented, or prohibited, depending on the circumstances. TCBS shall not be liable for any resulting loss, and TCBS expressly reserves all lawful rights in respect of such limitation, restriction, suspension, cancellation, prevention, or prohibition.

Article 14. Updates and Amendments

14.1. TCBS reserves the right to revise, modify, adjust, supplement, or update this Notice at any time, ensuring such changes comply with applicable laws.

14.2. Notice of any amendments will be published on TCBS’s website and/or via other communication channels as TCBS deems appropriate. TCBS recommends that Customers regularly review this Notice to stay informed of changes and how TCBS protects Customers’ personal data.

14.3. The Customer’s continued use of TCBS websites, applications, or devices shall be deemed continued use of TCBS services and acceptance of this Notice and any related amendments.

Article 15. Cross-Border Transfer of Personal Data

15.1. To fulfill the processing purposes stated in this Notice, TCBS may need to provide/share the Data Subject’s personal data to TCBS’s relevant Partners, which may be located in Vietnam or in any other jurisdiction outside the territory of Vietnam.

15.2. When transferring personal data overseas, TCBS will require the receiving party to ensure the transferred personal data remains secure and confidential. TCBS undertakes to comply with legal obligations and regulations relating to cross-border transfer of personal data.

Article 16. Miscellaneous Provisions

16.1. The rights and obligations of TCBS and the Customer under this Notice do not replace, terminate, or modify, but rather supplement, the rights and obligations of the parties under any other document.

16.2. This Notice shall be Interpreted in accordance with and governed by the laws of Vietnam.

16.3. Any dispute arising out of or in connection with this Notice shall first be resolved through good-faith discussions and negotiations between TCBS and the Customer to protect each party’s lawful interests. If the dispute is not resolved within thirty (30) days, either party may submit the dispute to a competent court in accordance with the laws of Vietnam.