Introduction

Lotte Cinema Vietnam Company Limited (hereinafter referred to as "LOTTE Cinema Vietnam", "the Company" or "we") is committed to respecting and making every effort to ensure the security and rights of Data Subjects regarding Customer Personal Data. In the process of processing Customer Personal Data, we will implement and comply with the contents of the Personal Data Protection Policy for Customers purchasing on LOTTE Cinema Vietnam's online platforms, including the website https://www.lottecinema.com.vn/ ("Website"), the LOTTE Cinema Vietnam Application ("Application"), and other Customer Care channels (hereinafter collectively referred to as "Platforms") of LOTTE Cinema Vietnam (hereinafter referred to as the "Privacy Policy"). This Privacy Policy stipulates and governs LOTTE Cinema Vietnam's processing of Customer Personal Data in accordance with the law. For Customer Personal Data, LOTTE Cinema Vietnam is the Data Controller and Processor. This Privacy Policy is publicly posted on the website or at LOTTE Cinema Vietnam's offices, Lotte Cinema cinemas, and takes effect from 01/07/2023. LOTTE Cinema Vietnam reserves the right to amend or supplement this Privacy Policy at any time. LOTTE Cinema Vietnam will notify Customers of any amendments or supplements to the Privacy Policy and publish it publicly on the LOTTE Cinema Vietnam website. LOTTE Cinema Vietnam encourages Customers to regularly review the Privacy Policy to stay updated on the latest information to exercise their rights as Data Subjects.

1. Definitions and Explanations of Terms:

In this Privacy Policy, unless the context otherwise requires, the following terms shall have the following meanings:

Data Controller:	An organization that determines the purposes and means of the processing of personal data. In this context, it's usually Lotte Cinema.
Data Controller and Processor:	An organization that both determines the purposes, means, and directly processes personal data.
Data Processor:	An organization that processes personal data on behalf of the data controller, under a contract or other legal act.
Data Subject:	An individual to whom the personal data relates, typically a Lotte Cinema customer.
Affiliated Company:	Any organization that is directly or indirectly controlled by, controls, or is under common control with Lotte Cinema Vietnam.
Personal Data:	Any information relating to an identified or identifiable natural person, such as name, address, telephone number, and email address.
Program:	Activities, services, or benefits offered by Lotte Cinema to customers, such as loyalty programs or promotional offers.
Customer:	An individual who is interested in or has actually made a purchase on the online platform or directly at a Lotte Cinema store, regardless of whether or not they have a Lotte Cinema membership card.
Customer Consent:	A written or implied agreement from a customer to Lotte Cinema Vietnam regarding the processing of their personal data.
For online purchases:	A customer's consent is clearly and voluntarily expressed by (1) clicking and checking the box stating "I agree to the Membership Terms and Privacy Policy of Lotte Cinema Vietnam" or similar statements displayed on Lotte Cinema Vietnam's registration page, and simultaneously (2) clicking and checking the box to select the purpose of personal data processing.
Website:	Refers to the website lottecinema.com.vn.
Application:	Refers to the Lotte Cinema Vietnam mobile app.

2. Scope and purpose of processing Customer's Personal Data:

2.1. Scope of processing:

The personal data of Customers processed by LOTTE Cinema Vietnam includes:

a) Basic personal data:

1. • Full name at birth, other names (if any);
2. • Date of birth;
3. • Gender;
4. • Residential information (including permanent residence, temporary residence, current address, hometown, contact address; work address, office address, other contact information);
5. • Nationality;
6. • Personal images; information obtained from security systems (for customers shopping at the Cinema, e.g., audio and video recordings at areas with CCTV cameras);
7. • Email address; Phone number;
8. • Name, phone number, and address of the recipient (if using delivery services);
9. • Customer reviews, ratings (including text, images, and videos provided by customers) via LOTTE Cinema's customer service channels such as App/Website/Hotline/KakaoTalk/Email/Fanpage;
10. • For child customers (under 16 years old): Information about the child's parents or legal guardians as prescribed by law, designated by the People's Committee of the commune or Court as prescribed by law (collectively referred to as "Legal Representative"), including full name, contact phone number, and the relationship between the Legal Representative and the child customer;
11. • Purchase history;
12. • User activity history;
13. • Other information provided by the Customer to exercise their rights or requests and does not belong to the category of sensitive personal data;
14. • Any other data or information voluntarily provided by the Customer to LOTTE Cinema Vietnam through the Platform during the use of the service or when participating in LOTTE Cinema Vietnam's events that collect information, not belonging to the category of sensitive personal data;
15. • Other information associated with a specific individual or helping to identify a specific individual that does not belong to the category of sensitive personal data.
16. • When a Customer provides personal data of other individuals (e.g., contact information of another individual to place an order and have it delivered) to LOTTE Cinema Vietnam, the Customer understands that they are acting as a Data Controller for the provision of such personal data of those subjects to LOTTE Cinema Vietnam, and LOTTE Cinema Vietnam only processes the personal data of those subjects based on the agreement with the Customer for the Purposes of Processing as stated in Clause 2.2 of this Privacy Policy. Customers are responsible for ensuring that such individuals have been fully informed of the relevant Purposes of Processing and the processing of personal data as prescribed by law and have obtained their consent before providing such information to LOTTE Cinema Vietnam.

b) Sensitive personal data:

1. • Payment information, such as bank account numbers, credit card numbers, and other detailed transaction information;
2. • Account information, including login name and password, account usage history, detailed information about products or services that the Customer has purchased or obtained on LOTTE Cinema Vietnam's platform and system;
3. • Data related to the electronic platform or application: Technical information (including Internet Protocol (IP) address, customer login data, type and version of browser, language settings, time zone and location, types and versions of browser plug-ins, operating system and platform, international mobile device identifier, device identification, interactions on platforms and applications...);
4. • Transaction information and account information are secured and recorded by the following parties when the Customer makes a payment:
1. - VNPay: VNPay payment gateway (PCI DSS compliant).
2. - Momo: E-wallet (PCI DSS compliant).
3. - ZaloPay: E-wallet (PCI DSS compliant).
4. - Apple Pay.
5. - Banks (Onepay , VNPT Epay)
6. - LOTTE CNF: Postpaid wallet.
7. - Fundiin: Postpaid wallet.
8. - Home Paylater: Postpaid wallet.
9. - Muadee: Postpaid wallet.

2.2. Scope of processing:

LOTTE Cinema Vietnam processes Customer Personal Data for the following purposes (hereinafter referred to as "Purposes"):

a) General processing purposes:

1. • Providing and managing the Program, including but not limited to the following details:
2. • Program for accumulating and using points;
3. • Preferential programs for Customers such as discounts, promotions, and free use;
4. • Providing services/utilities to Customers/introducing new products and services of the Company based on the needs and habits of Customers during their participation in the Program;
5. • Other programs developed and provided to Customers.
6. • Performing necessary services or services that contribute to supporting the provision and management of the Program.
7. • Optimizing the Program (implementing marketing and communication campaigns to Customers to improve the effectiveness of the Program).
8. • Identifying, authenticating and verifying Customer information for the Program.
9. • Send to Customers by methods in accordance with the provisions of law the notices, advertising information, promotions, and documents related to the Program, products and/or services within the framework of the Program ("Marketing Program"), with the following contents:
10. • Content: Notices, advertising information, promotions, and documents related to the Program, products and/or services within the framework of the Program, including but not limited to marketing programs, promotions, customer care policies, warranty policies, gift programs, discounts, or other special offers, etc.
11. • Method, form: The Company will contact Customers via Call Center, email, text messages, applications, social networks, or other interactive channels and send notices, advertising information, promotions, and documents related to the Program, products and/or services within the framework of the Program.
12. • Product introduction frequency: Marketing and product introduction will be carried out according to the specific implementation plan of the Marketing Programs that the Company is or plans to implement and/or has registered to implement with the competent state agency.
13. • Contact, support communication with Customers, exchange between Customers and the Company, and handle valid requests from Customers.
1. - Respond to service requests and support needs of Customers (such as delivery services, product exchange - return services, etc.);
2. - Adjust, update, secure and improve products, services, applications, equipment, systems that LOTTE Cinema Vietnam provides and/or is managing.
3. - Market research, analysis of products and services, development of new products, statistics on customer information, consumer behavior, and utilization of detailed information related to Program (such as transaction value, transaction time, shopping location, and other related information) to support the company's operations and business.
4. - Detection and prevention of fraudulent activities, account hacking, or identity theft within the framework of the Program.
5. - Prevention or investigation of any fraud, illegal activities, misconduct, or omissions related to all operations of LOTTE Cinema Vietnam.
6. - Management of security, order, safety, and assets at the Cinema, including but not limited to: (i) controlling access to the Cinema; (ii) detecting and preventing fraudulent or improper use of facilities, products, and services; (iii) detecting and preventing violations; and/or (iv) conducting internal investigations into incidents and providing as required by the State agency.
7. - Storage of personal information and performance of internal management tasks, backup for disaster recovery or for other similar purposes.
8. - Investigation of accidents, resolution of disputes, complaints, and other activities to comply with the obligations under Vietnamese law.
9. - Compliance with legal regulations and requirements of competent state agencies, including but not limited to the obligation to disclose information, report as prescribed by law on promotion, record keeping, auditing, etc.
10. - Other lawful purposes consistent with the objectives of the Program and the business and operations of LOTTE Cinema Vietnam (if any).

(b) Purposes of Data Processing for the Online Platform (if any):

1. • Order management and operation: To handle issues related to customer orders.
2. • Transactions and payments: To confirm transactions and process payments related to customer orders.
3. • Account maintenance: To create, manage, update and maintain customer accounts, including loyalty programs or reward programs associated with the account.
4. • Customer service: To include contacting and responding to customer inquiries, requests, and complaints; to notify customers of any changes to products and orders.
5. • Personalization: To personalize the customer experience, such as identifying preferences and purchasing behavior to improve LOTTE Cinema Vietnam's services and deliver promotional messages that match customers' shopping needs.
6. • Security: To serve the purpose of preventing malicious activities against customer accounts or fraudulent activities.
7. • Compliance with legal requirements: Depending on the provisions of the law at any given time, LOTTE Cinema may collect, store, and provide data as required by competent state agencies.

3. Organizations and individuals authorized to process Customer Personal Data:

LOTTE Cinema Vietnam will not provide Customer Personal Data to any third party outside of those involved in the Purposes of Processing. These related parties include:

1. • LOTTE CultureWorks Co., Ltd., and its Affiliates, branches and subsidiaries (if any);
2. • Service providers or other third parties involved in the operation of LOTTE Cinema Vietnam and in providing support for the Purposes of Processing, including but not limited to:
   1. - Logistics service providers;
   2. - Payment processors;
   3. - Data analytics partners (if any);
   4. - Cloud storage and IT infrastructure providers;
   5. - Advertising and marketing partners;
   - Advisors and consultants, such as legal advisors;
   7. - Auditors;
   8. - Advisors and consultants, such as legal advisors
   9. - Notary public, bailiff.
   10. - Competent state authorities;
   11. - Business transfers: LOTTE Cinema Vietnam may share Customer Personal Data with other parties in connection with any merger, acquisition, consolidation, joint venture, restructuring, financing or other business transaction.
   12. - Other third parties that LOTTE Cinema Vietnam deems necessary for the Purposes of Processing or as required by law.

4. Rights and obligations of Customers regarding Personal Data:

4.1. Rights of Customers:

Customers, as data subjects, have the following rights regarding their Personal Data, unless otherwise provided by law:

1. • Right to be informed: Customers have the right to be informed about the processing activities of their personal data.
2. • Right to consent: Customers have the right to consent or refuse to consent to the processing of their personal data, unless the law permits the processing of personal data without the data subject's consent.
3. • Right of access: Customers have the right to access, correct or request correction of their personal data by logging into their account on the Platform and editing their personal information or by requesting LOTTE Cinema Vietnam to do so through customer service channels such as Hotline/ KakaoTalk/ Email/ Fanpage.
4. • Right to withdraw consent: Customers have the right to withdraw their consent.
5. • Right to erasure: Customers have the right to erase or request the erasure of their personal data.
6. • Right to restrict processing: Customers have the right to request the restriction of processing their personal data.
7. • Right to data portability: Customers have the right to request to be provided with their personal data.
8. • Right to object: Data subjects have the right to object to the processing of their personal data in order to prevent or limit the disclosure of personal data or its use for marketing or advertising purposes.
9. • Right to lodge a complaint: Customers have the right to lodge a complaint.
10. • Right to compensation: Customers have the right to claim compensation in case of a violation of the provisions on the protection of their personal data.
11. • Right to self-protection: Customers have the right to protect themselves according to the provisions of the Civil Code, other related laws, and Decree 13/2023/ND-CP on Personal Data Protection. Customers have the right to request that competent authorities take measures to protect their civil rights. Customers also have the right to file a complaint about the disclosure of personal information to third parties with the management board of LOTTE Cinema Vietnam.

The exercise of certain rights by Customers, such as the right to withdraw consent, erase data, restrict or object to the processing of data, may lead to LOTTE Cinema Vietnam being unable to perform the actions necessary to achieve the Purposes of Processing, or being unable to provide, support, or resolve Customer requests. LOTTE Cinema Vietnam shall not be liable to Customers for any damages arising from the exercise of these rights by Customers

4.2. Customer Obligations:

Customers, as data subjects, have the following obligations regarding their Personal Data:

1. • Self-protection of Personal Data: Customers shall request that organizations and individuals involved protect their Personal Data. If Personal Data is leaked due to force majeure or any fault of the Customer, the Customer shall bear the risks and damages that may occur.
2. • Data security: Customers shall be responsible for protecting and keeping their login information, password, and email safe. In addition, Customers shall promptly notify LOTTE Cinema Vietnam of any unauthorized use, abuse, or violation of the security, storage of their login information and password by third parties so that appropriate measures can be taken; or when discovering any errors or inaccuracies in their Personal Data or suspecting that their Personal Data has been violated.
3. • Respect and protect the Personal Data of others.
4. • Provide complete and accurate Personal Data to LOTTE Cinema Vietnam when agreeing to the processing of Personal Data.
5. • Promptly update LOTTE Cinema Vietnam of any changes to the Personal Data that the Customer has provided.
6. • Provide legal documents as requested by LOTTE Cinema to prove that you have obtained the necessary consent and permission from the survey participant or third party to provide their Personal Data.
7. • Comply with the provisions of the law on personal data protection and participate in the prevention and combat against acts that violate the provisions on personal data protection.

5. Data Processing Period:

LOTTE Cinema Vietnam will start processing your personal data from the time we receive your consent to the processing of your personal data (as defined in Article 1 of this Privacy Policy). Your personal data will be processed for the period necessary to fulfill the Purposes of Processing and to comply with relevant legal requirements (e.g., for tax and auditing purposes), or to fulfill obligations that LOTTE Cinema Vietnam has informed you of. Certain categories of personal data may be retained for a longer period than other personal data.

6. Personal Data Processing Methods:

6.1. Collection and Processing of Personal Data:

LOTTE Cinema Vietnam may collect your personal data through the following methods:

1. • Directly from Customer when Customer purchase tickets at the cinema or online.
2. • From interactions of Customer with Lotte Cinema, such as in-person meetings, phone calls, email, social media, surveys, or any other means of communication.
3. • From surveillance cameras installed at the cinema.
4. • From Lotte Cinema business partners, affiliates, LOTTE Cinema Vietnam's data sources (including public data, government data, and other sources).
5. • From other legal forms and means of collecting Personal Data.

After collecting Personal Data, LOTTE Cinema Vietnam will conduct one or more appropriate Personal Data processing activities such as: collecting, recording, analyzing, confirming, storing, editing, publicizing, combining, accessing, retrieving, recalling, encoding, decoding, copying, sharing, transmitting, providing, transferring, deleting, destroying Personal Data or other related actions to carry out the Processing Purposes or to meet the request to exercise the rights of Customers as Data Subjects (for example, the right to edit, update, provide, restrict the processing of Personal Data, ...) in accordance with the provisions of current law.

6.2. Processing of Personal Data collected from recording and filming activities in public places:

LOTTE Cinema Vietnam may collect and process data on images of individuals and information obtained from the security system (for example, recordings,video recordings in areas with CCTV cameras, including but not limited to the Cinema area, including the Cinema area, hallways, entrances, etc. and parking lots) for the purpose of protecting national security, social order and safety, the legitimate rights and interests of organizations and individuals in accordance with the provisions of law without the consent of the Customer.

At LOTTE Cinema Vietnam, the security system and CCTV operate 24/7 to ensure order and safety for customers, prevent crime, protect facilities and prevent fires. LOTTE Cinema Vietnam commits to only process Customer Personal Data in accordance with the contents of this Privacy Policy and the provisions of law.

6.3. Processing Personal Data of Children Customers:

LOTTE Cinema Vietnam processes Personal Data of children in accordance with the principle of protecting the rights and for the best interests of children. Before processing Personal Data of children, the Company will take appropriate measures to verify the age of children. The processing of Personal Data of children must have the consent of the parents or guardians as prescribed and in the case of children aged 7 years or older, the consent of the child regarding the processing of Personal Data is required, except in cases where the data processing does not require the consent of the Data Subject as prescribed by law.

6.4. Deletion of Customer Personal Data:

LOTTE Cinema Vietnam will irreversibly delete Customer Personal Data in the following cases:

1. • Data processing is not for the right purpose;
2. • The purpose of processing Personal Data agreed to by the Customer has been completed;
3. • The storage of Personal Data is no longer necessary for the operation of LOTTE Cinema Vietnam;
4. • LOTTE Cinema Vietnam is dissolved or no longer operating or declared bankrupt or terminated business operations in accordance with the provisions of law.

LOTTE Cinema Vietnam will take necessary steps to prevent access to or use of Personal Data for any purpose other than compliance with this Privacy Policy or for the purpose of safety, security, fraud detection and prevention of risks to information system safety, network security, and safety of Customer Personal Data.

6.5. Transfer of Personal Data Abroad:

LOTTE Cinema Vietnam may transfer or grant access to Customer Personal Data to overseas organizations, management departments (including LOTTE CultureWorks Co., Ltd., and Affiliates, units and branches (if any)) or overseas partners, service providers for processing in accordance with the Processing Purposes agreed to by the Customer. In some other cases, LOTTE Cinema Vietnam's partners, service providers based in Vietnam may use data processing equipment, systems located outside the territory of Vietnam to process Personal Data on behalf of LOTTE Cinema Vietnam. These cases are considered to be transferring Customer Personal Data abroad.

It should be noted that some countries may have lower or higher levels or practices regarding the protection of Personal Data than Vietnam. In all cases where Personal Data is transferred abroad, LOTTE Cinema Vietnam will strive to take appropriate measures to ensure the protection of Customers' Personal Data, including signing agreements and commitments on data security, selecting partners as Personal Data Processors that are suitable for clear tasks and only working when these partners have appropriate protection measures.

7. Measures to protect Personal Data:

LOTTE Cinema Vietnam will implement appropriate measures to protect Personal Data, including organizational and human management measures, and appropriate technical measures in accordance with legal regulations to detect and prevent leaks or violations of Personal Data, including but not limited to:

1. • Develop and promulgate regulations on Personal Data protection, clearly stating what needs to be done in accordance with legal regulations.
2. • Designate departments and personnel in charge of protecting Personal Data. Record and store system logs of Personal Data processing.
3. • Check network security for systems, means, and equipment serving Personal Data processing before processing, irreversibly delete or destroy devices containing Personal Data.
4. • Design security systems, access control, intrusion prevention, authentication, data encryption, data backup.
5. • Other measures as prescribed by law.

8. Possible consequences and unexpected damages:

Please note that, although LOTTE Cinema Vietnam always strives to ensure that the Customer's Personal Data is best protected in accordance with the law, LOTTE Cinema Vietnam cannot completely and absolutely eliminate all risks to Personal Data during the processing process. The transmission of information via the Internet or LOTTE Cinema Vietnam's internal information system still has certain risks arising from force majeure or incidents, cyber security crimes such as cyber attacks, cyber terrorism, illegal cyber espionage, disruption of data processing or leakage of Personal Data. In this case, LOTTE Cinema Vietnam will immediately take necessary actions to prevent, remedy, and minimize possible unexpected damages to Personal Data, and coordinate with competent state agencies to handle violations. The Customer also agrees that to the extent that reasonable measures have been taken to prevent such hazards, LOTTE Cinema Vietnam shall not be liable for damages caused by the actions of any third party that adversely affects the Customer's Personal Data beyond the control of LOTTE Cinema Vietnam.

9. Personal Data Protection Department:

If the Customer wishes to request to exercise his/her rights or has any questions, requests for support, concerns and complaints related to this Privacy Policy or LOTTE Cinema Vietnam's Personal Data processing activities, the Customer may contact LOTTE Cinema Vietnam via the following contact details:

PERSONAL DATA PROTECTION DEPARTMENT - LOTTE CINEMA VIETNAM COMPANY LTD

1. • Address: 3rd Floor, 469 Nguyen Huu Tho Street, Tan Hung Ward, District 7, Ho Chi Minh City, Vietnam.
2. • Phone: (028) 3775 2524 - 028 3775 2520
3. • Person in charge: (Mr.) Nguyen Uy Vu
4. • E-mail: nguyenuyvu1989@lotte.vn

LOTTE Cinema Vietnam will screen and verify the identity, authority to execute the Customer's request, or necessary information related to the Customer's request. LOTTE Cinema Vietnam may request the Customer to provide supporting information or documents to authenticate the request. After verification, LOTTE Cinema Vietnam will process the Customer's requests within the time limit prescribed by law.

10. Address of the unit collecting, managing and supporting Customers:

LOTTE CINEMA VIETNAM CO., LTD

1. • Tax code: 0302575928
2. • Head office: 3rd Floor, 469 Nguyen Huu Tho Street, Tan Hung Ward, District 7, Ho Chi Minh City, Vietnam.
3. • Hotline: (028) 3775 2524 - 028 3775 2520
4. • Email: cs@lotte.vn
5. • Customer care hotline: (028) 3775 2524 - 028 3775 2520
6. • Email: cs@lotte.vn

11. Commitment to protect Customer's Personal Data:

Customer's Personal Data on LOTTE Cinema Vietnam's Platform is committed to absolute confidentiality according to this Privacy Policy. The collection and use of Customer's Personal Data is only carried out with the consent of the Customer, except in cases where the law provides otherwise.

LOTTE Cinema Vietnam commits to:

1. • Not to use, transfer, provide or disclose to any third party (except for organizations and individuals who process Customer's Personal Data listed in Article 3 of this Privacy Policy) Customer's Personal Data without the permission or consent of the Customer, except in cases where the law provides otherwise.
2. • In case the information storage server or information system of LOTTE Cinema Vietnam is hacked, leading to the loss of personal data of Customers, LOTTE Cinema Vietnam will be responsible for reporting the incident to the authorities for timely investigation and handling and notifying Customers.
3. • Absolutely secure all online transaction information of Customers including invoice information, digitized accounting documents in the secure central data area of LOTTE Cinema Vietnam.