PRIVACY POLICY

VIETALITY – Healthy the Vietnamese Way

Version 1.0

Last updated: January 30, 2026

1. Introduction

This Privacy Policy ("Policy") describes how Vincent Holdings Co., Ltd. ("Company", "we", "us", or "our") collects, processes, and protects users' personal data when using the VIETALITY – Healthy the Vietnamese Way mobile application ("Application").

We are committed to protecting personal data in accordance with:

The Personal Data Protection laws of Vietnam
Decree No. 356/2025/ND-CP
Google Play and Apple App Store privacy policies
Vietality Terms of Service

The Application is currently available in its initial release stage. We provide a mobile application that enables users to track body metrics, physical activity, and nutrition data directly for end users. We process personal data solely for the operation of product features and do not provide personal data processing services to third parties. Users actively log in and control their own data.

2. Data Processing Principles

We comply with the following principles:

Collect only the minimum amount of necessary data
Maintain transparency regarding processing purposes
Ensure personal data security
Allow users to control their own data

3. Categories of Data Processed

3.1. Account Data (Firebase)

The Application requires users to register an account using an email address for the purposes of:

User authentication
Account management
Access recovery support

Account data may include:

Email address
Login authentication information

User account data (email address and authentication credentials) is collected by the Company and stored and processed by a third-party service provider, Firebase, on Google Cloud infrastructure operated by Google LLC.

3.2. Health Data (Stored on User Device)

The Application allows users to input and manage health-related information, including:

Height
Weight
Physical activity data
User-entered body condition information

This data is stored entirely on the user's device and is not transmitted to the Company's servers.

The Application is distributed through Google Play and the Apple App Store; therefore, any device-level data handling is also subject to the privacy policies of those platforms.

4. Purposes of Data Processing

We process data for the following purposes:

4.1. Account Data

Creating and maintaining user accounts
Securing access to the Application
Providing technical support

4.2. Physical Activity, Body Metrics, and Nutrition Data

Providing tracking functionality
Personalizing the user's fitness experience
Assisting users in managing personal activity, nutrition, and body metric data

We do not use data for advertising purposes and do not sell data to third parties.

5. Explicit User Consent

Before using features related to physical activity, body metrics, and nutrition data:

Users will be clearly informed.
Users must actively consent to the processing of data they provide.
Users may refuse or withdraw consent at any time by deleting their data or uninstalling the Application.
Users are encouraged to review and comply with the applicable privacy policies and terms of Google Play and the Apple App Store before installing and using the Application.

6. Sharing of Personal Data

We do not collect, store, control, or process users' physical activity, body metrics, or nutrition data on our servers.

Account Data provided by Users is stored and may only be disclosed in limited cases:

Upon lawful request by competent state authorities.
When necessary and proportionate to protect users' rights and safety.
With the User's explicit, specific, and lawful consent.

7. Data Storage and Retention Period

7.1. Account Data

Stored until the User requests account deletion.

7.2. Physical Activity, Nutrition, and Body Metrics Data

Stored on the User's device until:

The User deletes the data; or
The User uninstalls the Application, subject to Google Play and Apple App Store privacy policies.

8. User Rights

Users have the right to:

Access their personal data
Correct their data
Delete their data
Withdraw consent
File complaints regarding data processing

Users may delete data directly within the Application or uninstall the Application in accordance with Google Play and Apple App Store privacy policies.

9. Data Security

We implement reasonable security measures to protect personal data, including:

Data encryption
Access controls
Secure operating system storage mechanisms

We are not responsible for risks arising from:

Loss of devices
Devices that have been modified, rooted, jailbroken, or had standard security mechanisms disabled
Malware from third-party software

10. Cross-Border Data Transfer

In the current version of the Application:

Physical activity, nutrition, and body metrics data are not transferred outside the user's device.
Account Data may be stored and processed by Firebase on Google Cloud infrastructure operated by Google LLC.

11. Policy Updates

This Policy may be updated when:

Application functionality changes
Backend systems are implemented
Legal regulations change

Users will be notified of material changes.

By continuing to use the Application, Users confirm that they have read and understood this Policy.

12. Contact Information

Vincent Holdings Co., Ltd.

Email: dev@vincentsoftware.com

Phone: +84 28 2213 0935

Address: 7th Floor, TOJI Building, 384/1C Nam Ky Khoi Nghia Street, Xuan Hoa Ward, Ho Chi Minh City, Vietnam