Ecoon Agency (operating as EcoonLiving) is committed to protecting your privacy and handling your personal data in accordance with the laws of Vietnam, specifically Decree No. 13/2023/ND-CP on Personal Data Protection (PDPD) and the Law on Cybersecurity. This means we:
- Clearly specify our purposes before we process personal data, by using this privacy statement;
- Limit our collection of personal data to only the data needed for lawful and legitimate purposes;
- Ask for explicit consent to process your personal data where required by law;
- Take appropriate technical and organizational measures to protect your personal data and demand the same from parties who process data on our behalf;
- Respect your rights as a data subject, including the right to access, correct, delete, or restrict the processing of your data.
Ecoon Agency is the Personal Data Controller responsible for all data processing. In this privacy policy, we will explain what kind of personal data we collect and for which purposes within our application EcoonLiving and website https://www.ecoon.vn/. We recommend that you read it carefully.
Definitions
Data Controller: Ecoon Agency (or "We") is the party that decides the purposes and means of processing personal data.
Personal Data: Information in the form of symbols, letters, numbers, images, sounds, or similar forms on an electronic environment that is associated with a specific person or helps identify a specific person. This includes Basic Personal Data (e.g., name, DOB) and Sensitive Personal Data (e.g., health status, financial data, location).
Data Subject: An individual to whom the personal data relates (e.g., You).
User: Anyone who registers an account with EcoonLiving.
Tenant: Anyone searching for accommodation to rent on EcoonLiving.
Host/Advertiser: Anyone seeking to list, rent, or sublet their property on EcoonLiving.
Third-Party: Any affiliate service or Data Processor that EcoonLiving does business with.
1. Registration on the EcoonLiving Platform
Certain features of our service require you to register. You will need to provide information to set up your account.
For this purpose, we use your full name, email address, phone number, and date of birth. We retain this data to manage your account, facilitate the execution of rental agreements, handle invoicing/payments, and provide customer support.
2. Information You Choose to Give Us
You can choose to provide additional personal information. This includes:
- Profile Information: When listing or booking accommodation, we may ask for an address, preferred language(s), and a profile picture. Some of this information (as indicated in settings) will be part of your public profile.
- Documents Requested by Hosts: Hosts may request documents to draft rental contracts, such as Citizen ID (CCCD/CMND), proof of occupation/enrollment, or proof of income. If a Host requires these, they must agree to use them solely for creating the rental agreement.
- Sensitive Personal Data: If you choose to share health information (e.g., disability access requirements) or financial data (payment linking), we process this Sensitive Personal Data strictly with your explicit consent and higher security standards as required by Decree 13.
3. Information Collected Automatically
By using the EcoonLiving Platform and Payment Services, we automatically collect specific data, including:
- Usage Data: Pages viewed, searches, bookings, and interactions.
- Device & Log Data: IP address, access times, hardware/software info, unique device identifiers, crash data, and cookies.
- Transaction Data: Payment instrument used, amount, expiration date, and transaction history.
- Identity Verification: Images of government-issued ID (CCCD/Passport) or facial verification data if required for fraud prevention and legal compliance (e.g., temporary residence registration).
4. Receiving Data from Third Parties
If you sign up via a Third-Party Service (e.g., Facebook, Google, Zalo), you authorize them to send us information such as your profile details and friends list, controlled by your privacy settings on that service.
5. Why Does EcoonLiving Collect and Use Your Data?
a. To provide our services
We use data to handle reservations, process payments, and ensure smooth service. We also use it to send service updates and notifications via email or app push notifications.
b. Fraud prevention and safety
We may review or scan communications for fraud prevention, risk assessment, and regulatory compliance. This helps prevent scams, such as requests for money transfers outside the EcoonLiving platform.
c. Sending newsletters
With your explicit consent (opt-in), we use your email to send news, tips, and promotions. You may unsubscribe at any time.
d. Statistical research and profiling
We use aggregated (anonymized) data to improve our services and for internal research. We may also use profiling to detect fraudulent behavior.
6. Legal Basis for Processing
Under Decree 13/2023/ND-CP, we process your data based on:
- Consent: Your explicit agreement to this policy and specific data collection actions.
- Contract Performance: Necessary to fulfill the rental or service agreement between you and EcoonLiving or the Host.
- Legal Obligation: Compliance with Vietnamese laws (e.g., tax reporting, cybersecurity data retention).
- Protection of Life/Health: In emergency situations protecting the data subject or others.
7. Providing Data to Third Parties
We do not sell your personal data. We share data only with:
- Hosts/Tenants: Essential contact info to conclude a booking.
- Service Providers (Data Processors): Cloud hosting, payment gateways (e.g., MoMo, VNPay), data analytics, and customer support tools. These parties are contractually bound to protect your data.
- Legal Authorities: If required by Vietnamese law (e.g., Ministry of Public Security) for investigation or national security purposes.
8. Security and Retention
Security
We implement technical and organizational measures compliant with Vietnamese Cybersecurity Law and Decree 13 (including encryption, access controls, and firewalls) to prevent unauthorized access, loss, or damage.
Retention
- We store data as long as necessary to provide services and resolve disputes.
- Cybersecurity Law Compliance: Certain data (user logs, IP addresses) may be stored for a minimum of 24 months as required by the Law on Cybersecurity for investigation purposes.
- Financial Data: Retained according to tax and accounting laws.
- Document Deletion: Rental documents are retained for a maximum of 12 months after account inactivity or 6 months after move-out, unless deletion is requested sooner.
9. Rights of the Data Subject
Under Decree 13, you have the following rights regarding your personal data:
- Right to Know: To be informed about how your data is processed.
- Right to Consent: To agree or disagree with processing.
- Right to Access: To view, rectify, or request correction of your data.
- Right to Withdraw Consent: To withdraw consent at any time (this does not affect the lawfulness of processing prior to withdrawal).
- Right to Delete: To request deletion of your data (unless legal retention obligations apply).
- Right to Restrict Processing: To request a restriction on processing your data (we will respond within 72 hours).
- Right to Data Provision: To request a copy of your data.
- Right to Object: To object to data processing for marketing purposes (we will respond within 72 hours).
- Right to Complain/Denounce: To file a complaint with the authority (Dept of Cybersecurity & Hi-tech Crime Prevention).
- Right to Claim Damages: If violations cause you harm.
- Right to Self-Protection: To protect your own data according to the law.
To exercise these rights, contact us at support@ecoon.vn. We may request ID verification (CCCD) to process your request.
10. App Permissions (Android & iOS)
- Push Notifications: We request permission to send booking updates and promos. You can manage this in device settings.
- Camera/Photos: Required only if you choose to upload profile photos, property images, or scan documents.
- Location: (If applicable) Used to show properties near you.
- App Tracking (iOS): We may request permission to track activity for personalized ads. You can decline this without affecting app functionality.
11. Contact Information
If you have questions about this policy or wish to exercise your rights, please contact our Data Protection Department:
Ecoon Agency (EcoonLiving)
Email: support@ecoon.vn
Website: www.ecoon.vn
Supervisory Authority: Department of Cybersecurity and High-Tech Crime Prevention (A05) - Ministry of Public Security, Vietnam.