PERSONAL DATA PROCESSING POLICY
UNION PQ CO., LTD (trademark UNION MARINA)
website unionmarina.vn, Phu Quoc Island, Socialist Republic of Vietnam
This Personal Data Processing Policy (the "Policy") sets out the procedure for collecting, storing, using, transferring and protecting the personal data of users of the website https://unionmarina.vn (the "Website") and guests booking services, by CÔNG TY TNHH UNION PHÚ QUỐC (UNION PHU QUOC COMPANY LIMITED, abbreviated as UNION PQ CO., LTD, trademark "UNION MARINA") (the "Company", "Operator"). The Policy has been developed in accordance with the personal data protection legislation of the Socialist Republic of Vietnam, including Decree No. 13/2023/NĐ-CP "On Personal Data Protection" and other applicable regulations.
By using the Website, submitting a booking request, filling in feedback forms or otherwise transmitting personal data to the Company, the data subject confirms that they have read the terms of this Policy and gives their free, specific, informed and unambiguous consent to the processing of their personal data under the terms set out below.
1. Terms and Definitions— "Personal data" — any information relating to a directly or indirectly identified or identifiable natural person (data subject).
— "Processing of personal data" — any action (operation) or set of actions performed with personal data, including collection, recording, systematization, accumulation, storage, clarification, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, destruction of personal data.
— "Data subject" ("User", "Guest", "Customer") — a natural person whose personal data is processed by the Company in connection with the use of the Website and/or booking and provision of services.
— "Operator" — CÔNG TY TNHH UNION PHÚ QUỐC (UNION PQ CO., LTD), organizing and/or carrying out the processing of personal data independently or jointly with third parties.
— "Website" — the internet resource https://unionmarina.vn and its language versions, including booking and feedback forms.
2. Personal Data Operator2.1. The processing of personal data for the purposes set out in this Policy is carried out by: CÔNG TY TNHH UNION PHÚ QUỐC (UNION PHU QUOC COMPANY LIMITED, UNION PQ CO., LTD), enterprise registration number 1702345751, registered address: Căn nhà B6-905, Phú Quốc Waterfront, Khu phố Đường Bào, Đặc khu Phú Quốc, Tỉnh An Giang, Việt Nam; email: info@unionmarina.vn; phone: +84 977 01 85 01.
2.2. For questions regarding the processing of personal data, the exercise of the data subject's rights, and to withdraw consent to processing, you may contact the Operator using the contact details specified above.
3. Categories and Composition of Personal Data Processed3.1. When booking services through forms on the Website, by phone, email or messengers (WhatsApp, Telegram, Zalo, KakaoTalk, etc.), the Operator processes the following personal data:
— surname, first name;
— contact phone number;
— email address (if provided);
— place of residence on Phu Quoc Island (district/hotel — for the purpose of organizing transfer, including cases of applying an additional transfer fee for the North Island area);
— information about the selected program, date, number of guests;
— payment data to the extent necessary for settlements (without storing full payment card details, the processing of which is carried out by the payment provider);
— other data voluntarily provided by the data subject when contacting the Operator (including in reviews, requests, correspondence).
3.2. When visiting the Website, technical data may also be automatically collected: IP address, browser type and version, interface language, cookies and similar technologies, data on visited pages and actions on the Website, used for the purposes specified in Section 4 of this Policy.
3.3. The Operator does not collect special categories of personal data (health status, religious beliefs, etc.), except in cases where the data subject voluntarily provides such information (for example, dietary restrictions or health conditions relevant to safety on board), and exclusively for the purpose of ensuring safety and quality of service provision.
4. Purposes of Personal Data Processing— receiving, processing and confirming booking requests for programs (day catamaran cruise, sunset cruise, private charter, individual Yamaha FC-27 boat rental, VIP fishing, etc.);
— organizing the provision of services, including "hotel — pier — hotel" transfer, including calculating and charging an additional transfer fee for guests of the North Island area;
— making settlements, invoicing, refunds;
— communicating with the Guest regarding booking matters (confirmation, schedule changes, cancellation, informing about weather conditions and other circumstances affecting the provision of services);
— ensuring safety on board vessels/boats and proper quality of service;
— reviewing requests, complaints and feedback;
— sending informational and promotional messages about the Company's programs and promotions — exclusively with the separate consent of the data subject, with the ability to unsubscribe from such mailings at any time;
— fulfilling the requirements of Vietnamese legislation (accounting, tax reporting, responding to requests from authorized bodies);
— improving the Website's operation, analyzing attendance and user experience (anonymized and aggregated statistics).
5. Legal Grounds for Processing— consent of the data subject, expressed when filling in forms on the Website, submitting a booking request, or in another manner of communication with the Operator;
— the necessity of performing a contract (public offer) to which the data subject is a party, or taking measures at their request prior to concluding a contract;
— the necessity of complying with legal obligations imposed on the Operator by current Vietnamese legislation;
— legitimate interests of the Operator (ensuring safety of service provision, protection against fraudulent actions) that do not violate the rights and freedoms of the data subject.
6. Procedure and Conditions for Processing Personal Data6.1. Personal data processing is carried out with the use of automation tools and without them (including on paper — for example, when filling in paper forms at the pier).
6.2. The Operator processes personal data only to the extent necessary to achieve the specific, predetermined and lawful purposes specified in Section 4 of this Policy, and does not allow processing incompatible with these purposes.
6.3. Personal data is stored no longer than necessary for the purposes of its processing, unless a different storage period is established by Vietnamese legislation (in particular, requirements for the storage of accounting and tax documents). Upon expiration of the storage period, personal data is depersonalized or destroyed.
7. Transfer of Personal Data to Third Parties7.1. The Operator has the right to transfer the Guest's personal data to the following categories of third parties exclusively to the extent necessary for the provision of services:
— transport partners and drivers carrying out "hotel — pier — hotel" transfer, including additional transfer for the North Island area;
— payment systems and banks — for making settlements;
— telecommunications operators and messenger providers (WhatsApp, Telegram, Zalo, KakaoTalk, etc.) — for sending messages related to booking;
— Vietnamese government authorities — in cases provided for by legislation (upon a reasoned request or by direct legal requirement).
7.2. The Operator does not transfer personal data to third parties for marketing purposes without the separate consent of the data subject and does not sell personal data.
7.3. In the case of cross-border transfer of personal data (for example, when using foreign communication services, hosting or payment systems), the Operator ensures compliance with the requirements of Vietnamese legislation on cross-border transfer of personal data, including the application of necessary contractual and organizational protective measures.
8. Personal Data Protection Measures8.1. The Operator takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, as well as from other unlawful actions of third parties, including:
— limiting the range of persons with access to personal data to those necessary for the performance of their labor (official) duties;
— using secure communication channels and information storage means;
— regularly assessing the effectiveness of the protective measures taken.
8.2. In the event of an incident resulting in a leak or other unlawful disclosure of personal data, the Operator takes reasonable measures to remedy the consequences and, if there is a corresponding obligation under Vietnamese legislation, notifies the authorized bodies and affected data subjects.
9. Rights of the Data Subject9.1. The data subject has the right to:
— receive information from the Operator regarding the processing of their personal data;
— require clarification, correction, blocking or destruction of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing;
— withdraw consent to the processing of personal data at any time by sending a corresponding request to the Operator using the contact details specified in Section 2;
— object to the processing of their personal data for direct marketing purposes;
— file a complaint regarding the processing of their personal data with the authorized government body of Vietnam, as well as in court.
9.2. Withdrawal of consent to processing of personal data does not affect the lawfulness of processing carried out by the Operator prior to such withdrawal, and does not prevent the processing of data to the extent necessary for the performance of already commenced contractual obligations (for example, completing a paid booking) or for compliance with legal requirements.
9.3. The Operator reviews requests from data subjects and provides a response within the period established by applicable Vietnamese legislation, but no later than 30 (thirty) calendar days from the date of receipt of the request, unless a different period is established by law.
10. Cookies and Similar Technologies10.1. The Website may use cookies and similar technologies to ensure the correct operation of booking forms, remember language settings, analyze attendance and improve the usability of the Website.
10.2. The User may independently manage the use of cookies in their browser settings, including disabling them; in this case, certain Website functions (in particular, booking forms) may not work correctly.
11. Processing of Personal Data of Minors11.1. The Website and the Company's services are not intended for independent booking by persons who have not reached the age of majority. The personal data of minor guests (for example, when arranging a family trip) is processed on the basis of data provided by their legal representatives (parents, guardians), who are responsible for the lawfulness of such provision.
12. Amendment and Validity of the Policy12.1. The Operator has the right to make changes to this Policy. The current version of the Policy is always posted on the Website at https://unionmarina.vn ("Personal Data Processing" section).
12.2. Continued use of the Website and/or the Company's services after changes are made to the Policy means the data subject's agreement with the current version of the Policy.
12.3. This Policy is valid indefinitely until replaced by a new version.
13. Contact Information of the OperatorFull name (in Vietnamese): CÔNG TY TNHH UNION PHÚ QUỐC
Full name (in English): UNION PHU QUOC COMPANY LIMITED
Abbreviated name: UNION PQ CO., LTD
Trademark: UNION MARINA
Enterprise registration number (Mã số doanh nghiệp): 1702345751, issued by the Department of Planning and Investment (Business and Cooperative Registration Division) of An Giang Province on 26.12.2025, amendment No. 1 dated 09.01.2026
Registered address: Căn nhà B6-905, Phú Quốc Waterfront, Khu phố Đường Bào, Đặc khu Phú Quốc, Tỉnh An Giang, Việt Nam
Director (legal representative): Hoàng Trung Nhân, citizen of Vietnam
Phone: +84 977 01 85 01
Email: info@unionmarina.vn
Website: https://unionmarina.vn
Publication date of this version: September 21, 2026
