Privacy policy

Note that this policy also apply to apps published at Play Store.

Our Purposes and Lawful Basis for Data Collection

Purpose and Basis for Data Processing

Your personal data is processed for various purposes, each requiring a lawful basis as specified by regulations. The bases we use include:

• Consent: You have provided informed, unequivocal, and specific consent for your personal data to be processed for a particular purpose.
• Legal Obligation: Certain laws require us to process and disclose data to specific institutions, such as the Tax Authority.
• Execution of a Contract: Data necessary to provide you with our services or to fulfill our contractual agreements.
• Legitimate Interests: Our legitimate interests are pursued, provided they do not override your interests and rights.
• Research: Research to improve our products and user experiences.

Data Processing on Our Website

Browsing the Website
When you browse and use our Website, even without registering, data is automatically collected through technology and automated interactions. This includes your IP address, device ID, and certain metadata (such as HTTP headers and browser information). We also collect information on the number of downloads and searches you perform.

These data are used to help us detect and mitigate risks such as bot attacks, code injections, and DDoS attacks, ultimately ensuring the security and maintenance of our Website.

• Lawful Basis: Our legitimate interest in protecting the security of our systems and preventing terms and conditions violations.
• Personal Data Processed: IP address, device ID, and certain metadata such as browser type and HTTP/HTTPS headers.

Contractual Relationship with Our Subscribers (Free or Premium)

When you register as a subscriber (either free or “premium”), we collect the personal data necessary to manage and fulfill our commitment to you.

If you are required to provide personal data due to legal obligations or our contractual conditions, and you refuse, we may not be able to formalize the contract or provide the service, which will be communicated to you accordingly.

• Personal Data Processed for Free Subscribers: Username, email address, name, address, and profession (only the email address and username are mandatory).
• Personal Data Processed for Premium Subscribers: In addition to the above, country, city of residence, tax residence, and payment method (all data are mandatory).

You can register on Nguyen Media using your account on other platforms, such as Google, through federated login available on our websites. This allows you to access Nguyen Media without creating and remembering a specific username and password.

This option is possible due to the collaboration between Nguyen Media and Google as joint controllers of your personal data processing. This means:

• You can identify yourself directly on these platforms.
• They confirm your identity.
• We provide you with login access as a registered user on Nguyen Media.

With your prior consent, Nguyen Media obtains your username, image, and email address from these platforms to register you. In turn, these platforms collect online identifiers (IP address), technical identifiers (from your device and their advertising identifiers such as your “Google ID”), and record the date and time of each access to Nguyen Media.

For more information, refer to Google Privacy & Terms.

You can exercise your rights to access, rectify, erase, limit processing, portability, and revoke consent concerning personal data obtained from these platforms (and other data provided to Nguyen Media) by contacting Nguyen Media at our contact form on our website.

Please note that rectifying or deleting your data in your Nguyen Media account does not automatically rectify or delete your data on the platforms that authenticate your identity. You must also contact them to exercise your rights.

To exercise your data protection rights related to any other data from your relationship with these platforms, you should contact the relevant platform directly.

Personalized Advertising on Nguyen Media and Other Websites

We promote our products:

• Through Social Networks and Other Platforms: We target potential Nguyen Media users using audience segments based on interests provided by platforms such as Pinterest, Google, and Twitter. These segments are not created by Nguyen Media but are offered by these platforms and utilized by us for advertising. We can only identify you if you register as a user.
• Lawful Basis: Our legitimate interest in acquiring new clients through personalized advertising based on profiling offered by social media and other platforms.
• Personal Data Processed: We do not directly process personal data. Instead, we select user groups for advertising based on segments offered by the platforms, such as age ranges or country. The platforms provide us with aggregated performance data for each campaign, but we cannot identify specific users who have registered as a result.
• Through Retargeting: We target visitors who have visited and left our Website without registering. If they have accepted the use of our cookies, these allow us to display advertising to them on third-party websites.
• Lawful Basis: Your consent (given both on our Website and on third-party websites where the advertising is displayed).

Sending of Commercial Communications by Email

We will send you electronic commercial communications if (i) you have registered or contracted any of the Website Services, or (ii) you request information about our products through any of the forms on the Website. We will do so as long as you have not expressed your objection to receiving such communications (you can opt-out via the specific slider in your user profile or by using the “Unsubscribe” button in each communication).

We will also send you content updates from creators you follow, provided you have specifically consented to this via the slider in your user profile. You can revoke your consent by unchecking it.

Advertisements on Our Website

We display personalized advertisements on our Website if you consent to the installation of cookies.

When we use cookies, it is based on your prior consent. You can accept or reject all our cookies or select them.

Personalized Advertising Through Preference Forms

We offer voluntary surveys to gather information about your basic user profile and preferences. This helps us personalize your experience on our websites, the advertising we display, and the information we send you based on the profile you provide.

The purpose of processing this data is to tailor our advertising and information to your preferences, enhancing your experience. Our legitimate interest is in continuously improving our products and services and obtaining relevant information in a transparent, respectful, and engaging manner.

• Personal Data Processed: Username, type of use of our products (personal, freelance, company and its approximate size, and industry or activity of the user), and personal preferences filled in the form.

You can object to this processing by simply omitting the survey response and closing the screens.

Surveys

We may contact you to request your opinions and preferences through satisfaction surveys based on our legitimate interest in improving our products’ performance and usability.

Additionally, to further our legitimate interests in improving our products and increasing sales, we may invite you to participate in surveys. These surveys aim to gather your opinions and preferences about our products to identify and eliminate any friction, facilitate their use, and enhance your interactions with them. Therefore, we will reach out to you for feedback through satisfaction surveys.

• Personal Data Processed: Contact information.

Support Requests

When you contact us requesting information, support, or feedback, we process your data to assist you based on the consent you express in your request.

• Personal Data Processed: Contact information you provide, as well as the content of your request.

Third-Party Integrations, APIs, Plugins, and Extensions

We may integrate or utilize various third-party extensions, add-ons, APIs, plugins, and other technologies (collectively, “Third-Party Integrations”) within our platform or services. These Third-Party Services are operated and provided by independent companies that are not under our direct control.

Legally Binding Processing

In certain cases, we are legally obligated by various regulations (regardless of your consent) to process and/or transfer certain personal data to different entities. For example, this may include sharing data with the Tax Authority or law enforcement authorities upon their request.

• Personal Data Processed: Those specified in the applicable regulations.

Disclosure of Data

Nguyen Media does not transfer or share collected personal data with third parties external to the company.

Access by Third Parties Providing Services to Us

We may disclose personal information of our users to third parties only when it is strictly necessary for Nguyen Media to perform its functions and comply with the relevant Terms of Use of each website. Additionally, we may share personal information with other third parties to ensure compliance with applicable laws, including:

• Service Providers: To manage systems and information technology, such as hosting, broadband, IT security, or web analytics providers.
• Payment Platforms and Banks: To ensure the fulfillment of necessary transactions.
• Advertising Platforms, CRM, and Marketing Tools
• User Support Management Platforms
• Legal and Consultancy Services: Including lawyers, auditors, and financial institutions.

These services provided by third parties are essential for Nguyen Media’s business operations. The processing of personal data is always subject to a contract establishing the duties of the data processor towards the data controller (us). Under no circumstances will personal information be used for other purposes and will be managed in compliance with Nguyen Media’s policy guidelines, privacy policy, and applicable data protection regulations.

We exclusively choose top-tier service providers, leaders in their respective sectors, to protect your privacy and data rights. You can request the list of providers that have access to your personal data and the services provided by each through the email address provided in the exercise of rights section.

Advertising Exploitation

We commercially exploit the advertising shown on our website by third parties through “cookies” and similar technologies, always with your prior consent.

Social Media Plugins

Our website includes plugins that allow users to interact with third-party social networks such as Twitter or Pinterest (e.g., sending a publication or showing support). These plugins are indicated with the corresponding social network logo and require access to the relevant platform and your consent.

If you accept these plugins, the content will be transferred to the corresponding social network.

Data Flows Within the Nguyen Media

The Nguyen Media, to centralize administrative and business infrastructure functions and benefit from specialization and compartmentalization inherent in these structures, will process personal data within the group of suppliers, users, and employees based on our legitimate interests.

Depending on the case, this processing is mainly carried out as a processor and, exceptionally, as a joint controller (for executing strategic decisions).

• Data Origin: Each subsidiary collects relevant data directly from the data subject.
• Personal Data Processed: Basic identification and contact data, login data (single login), economic and professional data, image, audio and video data (for contractual management of suppliers—creators and models), and web browsing data and metadata (for IT processing and web security).

Processing Impact on User’s Web Experience

The single login or centralized management of user data by Nguyen Media allows us to:

• Facilitate access to services
• Improve user knowledge
• Offer products or services from other companies in the group
• Manage incident support and rights
• Enhance the security and transversal management of our services

Data subjects have the right to object to any of these processing operations based on our legitimate interests through the channels described in the following section.