Privacy_Policy

of the website unionmarina.vn — UNION PQ CO., LTD (trademark UNION MARINA)

Phu Quoc Island, Socialist Republic of Vietnam

This Privacy Policy (hereinafter referred to as the "Policy") defines the procedure for using the internet website https://unionmarina.vn and its language versions (hereinafter referred to as the "Website"), the principles of collecting and using information about Website visitors applied by CÔNG TY TNHH UNION PHÚ QUỐC (UNION PHU QUOC COMPANY LIMITED, abbreviated name — UNION PQ CO., LTD, trademark "UNION MARINA", hereinafter referred to as the "Company", "We", "Us"), as well as the terms of use for cookies, widgets, and services of third-party providers integrated into the Website.
Issues directly related to the processing of guests' personal data when booking services (data composition, purposes, grounds, retention periods, rights of the personal data subject) are regulated by a separate document — "Personal Data Processing Policy" published on the Website. This Policy applies in addition to it and describes the general privacy rules when using the Website as such.
The use of the Website (viewing pages, clicking links to messengers and social networks) signifies the User's familiarity with this Policy and acceptance of the general rules for using the Website. Visiting the Website by itself is NOT considered as consent to the processing of personal data within the meaning given to such consent by the applicable legislation of Vietnam: legally significant consent to the processing of personal data is requested separately and recorded separately at the time of filling out the booking form or any other form requiring the provision of personal data, in accordance with the procedure described in Section 4 of this Policy and in the "Personal Data Processing Policy". Consent to receive marketing (advertising, informational) mailings and the selection of non-essential categories of cookies are separate, voluntary, and are not included in the general agreement with this Policy.
If the User does not agree with this Policy, they should stop using the Website; at the same time, rejection of the general rules for using the Website does not prevent the User from exercising the rights provided for in Section 12 of this Policy.

1. Terms and Definitions

"Website" — the internet resource located at https://unionmarina.vn, including all its language versions (Russian, English, Vietnamese, Chinese, Korean).
"User" — any individual visiting and using the Website.
"Company" ("We", "Us", "Website Administration") — CÔNG TY TNHH UNION PHÚ QUỐC (UNION PQ CO., LTD), the owner and administrator of the Website, acting as the controller (operator) of personal data within the meaning of the applicable legislation.
"Information" — data about the User obtained by the Website automatically or provided by the User voluntarily when filling out forms on the Website.
"Personal Data" and "Processing" — are used in the meaning established by the legislation of Vietnam on the protection of personal data specified in Section 2 of this Policy.
"Cookies" — small text files and similar technologies (pixels, local storage) saved by the browser or device of the User when visiting the Website.
"Third-Party Services" ("Widgets") — software solutions of third-party providers embedded into the Website (website builder, maps, weather informant, buttons and messengers of social networks, etc.).
"Legal Representative" — a parent, adoptive parent, guardian, or trustee of a minor acting on their behalf in accordance with the procedure established by law.
"Sensitive Data" — special categories of personal data (in particular, health data, including dietary restrictions and allergies) requiring enhanced security measures in accordance with applicable legislation.

2. Applicable Legislation
2.1. This Policy has been developed and shall be interpreted in accordance with the legislation of the Socialist Republic of Vietnam on personal data protection and consumer rights protection, including (in the applicable part and subject to subsequent amendments):

Law on Personal Data Protection No. 91/2025/QH15, effective from January 1, 2026;
Decree No. 356/2025/NĐ-CP, detailing the procedure for the protection of personal data, effective from January 1, 2026;
Law on Consumer Rights Protection 2023 and Decree No. 55/2024/NĐ-CP — regarding the protection of consumer information and digital transactions;
Law on Electronic Transactions 2023 — in the applicable part of electronic interaction and online booking.

2.2. In the event of changes to the specified regulatory acts or the adoption of new applicable acts, the Company shall bring this Policy into compliance with the current legislation in the manner prescribed by Section 15 of this Policy.

3. What Information the Website Collects
3.1. Information provided voluntarily. When filling out feedback and booking forms on the Website ("Leave a request", "Book"), the User independently specifies their name, phone number and, if necessary, other data (program, date, number of guests). This information is used for the purposes described in Section 7 of this Policy and in the "Personal Data Processing Policy".
3.2. Information collected automatically. When visiting the Website, the following may be automatically recorded: IP address, type and version of the browser and operating system, interface language, data on transitions and actions on the Website pages, date and time of the visit, as well as other technical data transmitted by the User's browser. Such information is collected using cookies and similar technologies applied by the Website (see Section 6).
3.3. Special regime for sensitive data. The Website does not intentionally request special categories of data (health status, religious or political views, etc.) through feedback forms. If the User voluntarily provides such information — in particular, information about dietary restrictions, allergies, or other medical circumstances significant for the safe provision of the service on board — such data shall be processed in compliance with the conditions set forth in Section 11 of this Policy.

4. User Consent and Legal Grounds for Processing
4.1. The Company distinguishes three independent levels of consent/acceptance of terms:

familiarization with the general rules for using the Website — is deemed to have taken place upon visiting the Website (the section immediately following the preamble of this Policy);
consent to the processing of personal data for the purposes of booking and rendering services — is requested separately, explicitly, at the time of filling out the booking form or other request requiring the provision of personal data, and is regulated by the "Personal Data Processing Policy";
consent to receive marketing and advertising messages, as well as the choice of non-essential categories of cookies — is requested separately from the two above-mentioned levels, is voluntary, and can be revoked by the User at any time without prejudice to the use of the basic functions of the Website and booking of services.

4.2. The processing of personal data is carried out by the Company on the basis of: the consent of the personal data subject; the necessity to perform a contract (public offer) to which the personal data subject is a party, or to take steps at their request prior to entering into a contract; the necessity to comply with the legal obligations of the Company under the laws of Vietnam; the legitimate interests of the Company (ensuring the safety of service provision, preventing fraudulent activities) that do not violate the rights and freedoms of the personal data subject.

5. Cross-Border Data Transfer and Third-Party Services
5.1. The Website is created and functions on the Tilda technology platform (Tilda Publishing). When using the Website, certain technical functions (page hosting, feedback forms, anti-spam protection) may be processed involving the infrastructure of this platform in accordance with its own privacy policy.
5.2. The Website uses the following integrated services and widgets of third-party providers, each of which may collect technical information about the User in accordance with their own terms and privacy policies: Google Maps; weather informant (weatherwidget.org); buttons and widgets of messengers and social networks WhatsApp, Telegram, Zalo, KakaoTalk, Facebook, Instagram; FotoOwl photo gallery service.
5.3. A simplified data flow diagram is as follows: User → form on the Website (Tilda) → the Company's internal inquiry/booking tracking system (CRM/booking system) → in case of payment, payment provider/bank → transfer of data necessary for transfer and service rendering to carriers and crew → communication with the User via the chosen messenger → anonymized traffic analytics → data backup → other contractors engaged by the Company to support its activities.
5.4. Since part of the specified infrastructure (in particular, Tilda, Google, Meta (Facebook/Instagram), international messengers) may technically process and/or store data on servers outside of Vietnam, such processing may qualify as a cross-border transfer of personal data. The Company takes measures to ensure that cross-border transfers are carried out in accordance with the applicable legislation of Vietnam on personal data protection, including by: concluding contractual terms on data protection with the respective service providers (to the extent that this is technically and commercially possible for mass services used); limiting the scope of transferred data to the purposes necessary for the operation of a specific service; conducting assessments prescribed by law for cases where it is required due to the volume and nature of cross-border processing.
5.5. The Company has the right to update the list of third-party services used and accordingly update this section; the current list of integrated services primarily reflects the actual configuration of the Website as of the publication date of the Policy edition.

6. Cookies and Their Management
6.1. The Website uses cookies and similar technologies, which are divided into the following categories:

necessary (strictly required) — ensure the basic operation of the Website and booking/feedback forms; their use does not require separate consent of the User, as without them the correct operation of the Website is impossible;
functional — ensure remembering language settings and other user preferences;
analytical — used to collect anonymized traffic statistics in order to analyze and improve the operation of the Website;
third-party/embedded — associated with the operation of third-party service widgets listed in Section 5 (maps, messengers, social networks, photo gallery);
marketing/advertising — used to personalize advertising offers and evaluate the effectiveness of marketing campaigns, if such technologies are applied by the Company.

6.2. Necessary cookies are used without separate consent of the User due to their mandatory nature for the operation of the Website. Functional, analytical, third-party, and marketing cookies are used only with the consent of the User, which is requested upon the first visit to the Website via the corresponding banner/cookie management tool (Cookie Consent Manager).
6.3. The User has the right at any time to change the previously made choice regarding non-essential categories of cookies — through the cookie management tool on the Website (when available) or through their browser settings, including a complete block on saving cookies. Disabling necessary cookies may lead to the impossibility of the correct operation of individual functions of the Website, in particular booking forms.

7. Purposes of Information Use

processing of booking requests for programs and organizing the provision of services;
feedback with the User on issues related to the use of the Website and booking;
ensuring technical functionality, security, and stability of the Website;
analysis and improvement of the content and functionality of the Website;
sending marketing and informational messages — only if there is a separate consent of the User obtained in accordance with Section 4;
compliance with the requirements of the applicable legislation of the Socialist Republic of Vietnam, including consumer rights protection legislation.

8. Transfer of Information to Third Parties
8.1. The Company does not sell information collected through the Website to third parties and does not transfer it to third parties for marketing purposes without the User's consent.
8.2. Depending on the infrastructure actually used, information may be transferred to the following categories of recipients — solely in the scope necessary to achieve the purposes specified in Section 7 of this Policy, or in execution of legal requirements: the provider of the Website's technological platform (Tilda); the internal system for tracking inquiries and bookings (CRM/booking system) of the Company; banks and payment providers (payment gateway); carriers, shipowners, and crews involved in rendering the service and transfer; insurance companies — in cases where the service is accompanied by insurance; guides and other persons directly participating in rendering the service; providers of cloud services and backup; other contractors engaged by the Company to ensure the operation of the Website (for example, analytics services); state authorities of Vietnam — on the grounds provided for by law.
8.3. The Company strives to limit the circle of recipients and the volume of data transferred to them to the limits necessary for a specific purpose, and to work with contractors on the basis of contractual terms providing for obligations to protect personal data.
8.4. The terms of transfer of guests' personal data in connection with booking and rendering services are regulated in detail by the "Personal Data Processing Policy".

9. Third-Party Services and External Links: Limits of the Company's Liability
9.1. Third-party services specified in Section 5, as well as other resources to which the Website may contain links (social networks, messengers, maps, photo gallery services), operate on the basis of their own terms of use and privacy policies, which are not developed or controlled by the Company. The Company recommends that the User familiarize themselves with such terms when switching to the respective resources or using the respective widgets.
9.2. This clause does not limit or exclude the liability of the Company in cases where such liability cannot be excluded or limited in accordance with the mandatory rules of the legislation of the Socialist Republic of Vietnam, including in terms of the selection and integration of third-party services embedded by the Company into the Website infrastructure, and ensuring proper contractual guarantees of data protection when engaging them.

10. Data Retention Periods
10.1. The Company stores information no longer than necessary for the purposes of its processing, guided by the following rough criteria (specific periods are determined by the internal regulations of the Company taking into account actual IT processes and are subject to clarification upon request):

booking requests that did not result in the execution of the service — are stored for a limited period reasonably necessary to process the request and subsequent communication with the User, after which they are deleted or anonymized;
data on completed bookings and rendered services — are stored for the period necessary to perform the contract, consider possible claims, as well as during the periods established by the accounting and taxation legislation of Vietnam for the storage of primary documents;
technical journals and data collected automatically (logs, traffic statistics) — are stored for a limited period necessary for security and analytical purposes, after which they are deleted or anonymized;
cookies — are stored for periods determined by the settings of the respective category of cookies and the technical parameters of the services used (see Section 6); the validity period of specific cookies can be clarified through the cookie management tool on the Website;
data processed on the basis of marketing consent — are stored until such consent is revoked by the User or until the expiration of the period established by the internal regulations of the Company.

10.2. Upon expiration of the respective retention period, personal data are subject to deletion or anonymization, except for cases when further storage is necessary for the performance of the Company's obligations established by law, or to protect the legal rights and interests of the Company or third parties (in particular, in connection with a judicial dispute).

11.1. Certain information that the User may voluntarily communicate in connection with a booking (in particular, dietary restrictions, allergies, or other medical circumstances significant for safety on board) may contain information relating to health and is treated by the Company as sensitive data.
11.2. Such data is processed by the Company only in the scope necessary for a specific purpose — ensuring safe and high-quality service provision (for example, preparing meals taking into account restrictions or informing the crew about characteristics significant for safety) — and only for the period necessary to render the corresponding service, after which it is deleted or anonymized on a priority basis compared to other categories of data.
11.3. Access to sensitive data is limited to a circle of employees and partners of the Company (for example, the crew, catering supplier) who need such information directly for the purposes specified in clause 11.2, and is not used by the Company for other purposes, including marketing.

12. User Rights
12.1. In relation to their personal data processed by the Company through the Website, the User (personal data subject) has the right to:

be informed about the processing of their personal data;
give consent to the processing of personal data and withdraw previously given consent at any time;
gain access to their personal data and information about its processing;
demand the correction of inaccurate or incomplete personal data;
receive their personal data in a structured format for transmission to another operator, if applicable and technically feasible;
demand the deletion of their personal data in cases provided for by law;
demand the restriction of the processing of their personal data in cases provided for by law;
object to the processing of their personal data, in particular for direct marketing purposes;
file a complaint, apply for the protection of their rights, and demand compensation in cases and in accordance with the procedure provided for by the applicable legislation of Vietnam.

12.2. The realization of the listed rights may be limited in cases directly provided for by law — in particular, when further processing (including storage) is necessary for the performance of the Company's contractual obligations to the User, to comply with the legal duties of the Company (accounting, tax reporting, responses to requests from authorized bodies), or to protect the legal rights and interests of the Company or third parties.
12.3. To realize the specified rights, as well as on issues related to the use of cookies, the User may contact the Company using the contact details specified in Section 16 of this Policy. The detailed procedure and terms for considering such requests are established by the "Personal Data Processing Policy".

13. Children and Data of Minors
13.1. Independent use of the Website by a minor. The Website is not intended for independent use (including independent booking) by persons under 18 years of age without the participation of parents or other legal representatives. The Company does not carry out the purposeful collection of information about minor users acting independently.
13.2. Provision of a child's data by a legal representative. If a booking is made for a family or group including minors, the relevant child's data (name, age) is provided to the Company by the child's legal representative, who is responsible for the lawfulness of providing such data and confirms their right to act on behalf of the child. Data about the child is used by the Company exclusively for purposes related to the organization and safe provision of the booked service (including vessel capacity tracking and safety measures) and is not used for marketing purposes.
13.3. The legal representative has the right to realize the rights provided for in Section 12 of this Policy on behalf of the child.

14. Information Security
14.1. The Company takes organizational and technical measures to protect information obtained through the Website from unauthorized access, modification, disclosure, or destruction, including, in particular: role-based data access restriction for employees; use of secure communication channels; data backup; data deletion procedures upon expiration of retention periods; working with contractors on the basis of contractual obligations for data protection; as well as information security incident response procedures.
14.2. Despite the measures taken, no method of transmitting data over the Internet and no method of electronic storage can be considered absolutely secure; the Company exerts reasonable efforts to protect information but cannot guarantee its absolute security. In the event of detecting an incident that resulted in a leak or other unlawful disclosure of personal data, the Company takes reasonable measures to eliminate the consequences and, if there is a corresponding obligation under the laws of Vietnam, notifies the authorized bodies and affected persons.

15. Changes to the Privacy Policy
15.1. The Company has the right to make changes to this Policy from time to time, including in connection with changes in the legislation of Vietnam on personal data protection or the actual configuration of the Website and services used. A new edition of the Policy comes into force from the moment of its placement on the Website, unless otherwise provided by the new edition.
15.2. The current edition of the Policy is always available at https://unionmarina.vn. The Company recommends that Users periodically familiarize themselves with the text of the Policy to track possible changes.

16. Contact Information

Full 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 Office) 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
Phone: +84 977 01 85 01
Email: info@unionmarina.vn
Website: https://unionmarina.vn
Edition Publication Date: September 21, 2026