ZZIM Privacy Policy

Effective date October 1, 2026

CÔNG TY TNHH THƯƠNG MẠI VÀ ĐẦU TƯ NPY (the “Company”) values User privacy and is committed to protecting personal information securely in accordance with applicable law.

This Privacy Policy explains the collection, use, storage, and provision of personal information when Users use the ZZIM application (“ZZIM” or the “Service”) operated by the Company.

Article 1. Purpose of this Policy

This Privacy Policy sets out the purposes for which ZZIM collects Users’ personal information and how such information is used, stored, and protected.

Article 2. Personal Information Controller

  1. Personal information controller: CÔNG TY TNHH THƯƠNG MẠI VÀ ĐẦU TƯ NPY
  2. Service: ZZIM
  3. Enterprise registration number: 0110954993
  4. Representative: YANG MINKYU
  5. Head office: Hanoi, Vietnam
  6. Privacy inquiries may be submitted through the ZZIM customer support channel.

Article 3. Personal Information Collected

The Company may collect personal information necessary to provide the Service, including:

  1. Account registration and management: name or display name; phone number; email address; login account information; profile photo; country or nationality; gender, date of birth, and other information directly provided by the User.
  2. Bookings and Service use: booking name; contact information; booking date and time; number of people; requests; booking-related communications; and information the User chooses to provide to the Partner.
  3. Location information, when the User consents and uses relevant features: current or selected location; location data used to search nearby places; and information required for maps and location-based recommendations.
  4. AI and search features: search terms; conversations with AI; photos or images; menus or other images uploaded by the User; and information entered for AI translation or recommendations.
  5. Automatically generated information during use: IP address; device information; operating system; app version; access logs; Service usage history; error and failure records; and cookies or information generated through similar technologies.
  6. The Company collects personal information only to the extent necessary for actual operation of the Service.

Article 4. Purposes of Collection and Use

The Company uses collected personal information only for the following purposes:

  1. Account registration and identity verification when necessary.
  2. User account management.
  3. Submitting and confirming booking requests.
  4. Connecting Users and Partners and facilitating communication.
  5. Customer inquiries and support.
  6. Providing AI search, translation, recommendation, and consultation services.
  7. Providing services suited to User needs.
  8. Improving Service quality and analyzing errors.
  9. Preventing fraudulent use and abuse.
  10. Ensuring Service security and safety.
  11. Complying with legal obligations.
  12. Operating and managing the Service.

Article 5. Provision to Third Parties

  1. As a general rule, the Company does not provide Users’ personal information to third parties without User consent, except where otherwise permitted or required by law.
  2. When a User submits a booking request through ZZIM, the Company may provide the relevant Partner with information necessary to process the booking, including booking name, contact information, booking date and time, number of people, booking requests, and other information necessary to process the booking.
  3. The Company provides personal information to Partners only within the scope necessary to provide the service requested by the User.
  4. The Company may provide personal information to competent authorities when requested in accordance with legally prescribed procedures.

Article 6. Outsourcing of Personal Information Processing

  1. When necessary to operate the Service, the Company may outsource part of personal information processing to external professional service providers.
  2. Outsourced activities may include server and cloud operation; data storage and management; SMS or email delivery; customer support systems; AI service provision and processing; maps and location-based services; and security and system maintenance.
  3. The Company manages and supervises processors in accordance with applicable law to ensure personal information is processed securely.

Article 7. Overseas Transfer of Personal Information

  1. During operation of ZZIM, personal information may be stored or processed overseas when servers, cloud systems, AI systems, or other technology service providers are located outside Vietnam.
  2. When personal information is transferred overseas or processed overseas, the Company complies with procedures and protective measures required by applicable law.
  3. Where overseas transfer requires notification or consent, the Company will follow the procedures required by applicable law.

Article 8. Retention and Use Period

  1. The Company retains and uses personal information until the purposes of collection and use have been fulfilled.
  2. When a User requests account deletion or the purpose of processing has ended, the Company deletes or destroys personal information in accordance with applicable law.
  3. Information that must be retained for a specific period by law may be stored for the legally required retention period.
  4. Service usage records, booking records, and other transaction-related records may be retained for the period necessary to resolve disputes, prevent abuse, and comply with legal obligations.

Article 9. Deletion and Destruction

  1. When the retention period expires or the purpose of processing has been fulfilled, the Company destroys the relevant personal information without undue delay.
  2. Electronic personal information is, in principle, deleted by a method that prevents recovery or restoration.
  3. Paper documents containing personal information, if any, are destroyed by methods such as shredding or incineration.

Article 10. Security Measures

The Company may implement measures to protect Users’ personal information, including management of access privileges; access controls; encryption; operation of security programs and systems; management and monitoring of access logs; training of employees handling personal information; security incident prevention and response systems; and other measures required by applicable law.

Article 11. User Rights

  1. Within the scope provided by applicable law, Users may exercise rights relating to their personal information, including the right to know about processing; request access; request correction or updates; request deletion or destruction; request restriction of processing; withdraw consent where permitted by law; and exercise other rights recognized by law.
  2. Users may exercise these rights through the ZZIM customer support channel.

Article 12. Cookies and Automatic Collection Technologies

  1. ZZIM may use cookies or similar technologies to improve the Service environment and User convenience.
  2. Cookies may be used to maintain login status, analyze Service use, identify errors, and improve the Service.
  3. Users may restrict or refuse cookie storage through device or browser settings; however, some Service functions may not operate normally.

Article 13. Location Information

  1. With User consent, ZZIM may use location information to provide nearby-place searches, maps, location-based recommendations, and related features.
  2. For Services that do not require location information, Users may, where reasonably possible, use the Service without providing location information.
  3. Users may change or withdraw location permissions through device settings.

Article 14. AI Services and Personal Information

  1. ZZIM may provide AI search, recommendation, translation, and consultation features.
  2. When AI features are used, conversations, search terms, images, or other information entered by Users may be processed to provide those features.
  3. The Company manages personal information so that it is not used beyond the scope necessary to provide AI services.
  4. Users should avoid entering unnecessary sensitive personal information such as citizen identification numbers, passport numbers, passwords, or financial information when using AI features.
  5. AI-generated results are reference information only. Users should independently verify relevant information before making important decisions or bookings.

Article 15. Person Responsible for Personal Information Protection

  1. The Company may designate a person or department responsible for personal information protection and the protection of User rights.
  2. Privacy inquiries or requests to exercise rights may be submitted through the ZZIM customer support channel.

Article 16. Changes to this Policy

  1. The Company may amend this Privacy Policy in response to changes in applicable law or the Service operating environment.
  2. If there are material changes, the Company will provide advance notice through ZZIM of the changes and effective date.
  3. The amended Privacy Policy will be available on ZZIM from its effective date.

Supplementary Provision

  1. This Privacy Policy takes effect on [○ ○, 2026].
  2. Company: CÔNG TY TNHH THƯƠNG MẠI VÀ ĐẦU TƯ NPY
  3. Service: ZZIM
  4. Enterprise registration number: 0110954993
  5. Representative: YANG MINKYU