1 – Introduction

    - AceCom Technologies Pte Ltd (“AceCom”) respects the privacy and security of personal data of customers, partners, and others we interact with during the provision of services. We are committed to implementing policies, practices, and procedures to protect the collection, use, and disclosure of personal information you provide to us, in compliance with Decree No. 13/2023/ND-CP.

    - By submitting your information to us or registering for any products or services provided or distributed by us. You agree and allow AceCom as well as, where appropriate, our representatives, third-party service providers, and contractors to collect, use, and disclose personal data as set out in the current terms of this Privacy Notice, including any future amendments. You acknowledge and agree that AceCom may adjust and update this Privacy Notice to ensure it complies with legal requirements and future industry developments/trends.

    **** Please note that the purposes stated in this Privacy Notice supplement but do not replace any consent you may have previously provided to us or may provide to us in the future.

2 - How we collect your personal data

    - Personal data refers to any information that can uniquely identify an individual (a) independently, or (b) when combined with other information. Information related to businesses (e.g., full name, business address, business phone number) is not considered personal data, it is used strictly for business-to-business (B2B) transactions.

    - We collect your personal data when you:

•         + Sign an agreement or contract with us to provide you with consulting services and services we provide, distribute documents or other information related to your interactions and transactions with us or when you use our services.


•         + When you interact with our customer service representatives, sales staff, or appointed service providers (e.g., via phone calls, correspondence, direct meetings, social media platforms, surveys, seminars, or email).


•         + When you explore our unique collection of products and services.


•         + Respond via online email (EDMs) we send, as part of marketing or promotional campaigns through our official EDM service provider partner.


•         + Are referred to us by one of our reputable partners or co-business partners, as an opportunity for you to explore and experience the excellent services we offer.


•         + Request us to contact you (may be for more information, complaints, or any other purpose).


•         + Explore the utilities of our electronic services or interact through mobile services, accounts on social networks, digital platforms, any of our websites or web services, and take an important step by registering an account with us. Experience strong connectivity and diverse utilities anytime, anywhere - we are always ready to serve and make every interaction special.


•         + When we receive information from third parties about you when you make payments through payment means (including but not limited to physical and digital payment kiosks).


•         + Images recorded via camera (CCTV) or through photos, videos taken by us or our representatives or agents at our events to capture memorable and unique moments.


•         + Submit your personal information to us for any other reason.


•         + Other popular and appropriate public information sources when necessary.

    **** Please note that if you provide us with any personal data relating to a third party, you represent and warrant to us that you have obtained the consent of the third party to provide us with their personal data for the relevant purposes.

3 - Types of personal data we collect about you

    Types of personal data we collect about you include:

•         + Your contact information (Name, phone number, email address)
•         + Your personal information (Name, company name, date of birth, driver's license number, vehicle plate number, profile image, image/video)
•         + Shopping on our website (Name, credit card number, billing address, shipping address, and phone number)

    In addition to information we collect directly from you, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or from public information sources.

4 - Use of personal data

    We use the personal data you provide to us for one or more of the following purposes:

•         + Provide our products, services, and fulfill obligations from any contract signed between you and us.


•         + Respond to your questions, complaints, feedback, and requests or communicate with you about your contracts.


•         + Process, manage accounts payable, invoice, payment, and other credit-related activities.


•         + To fulfill individual requests or for purposes provided to us as stated at the time of collection (or as clear from the context of collection).


•         + Conduct direct marketing activities and generate leads through analysis and tracking of sales proposals, advertising, and EDMs at our events, seminars, and workshops.


•         + Customer care, enhance customer experience, and manage accounts.


•         + Analyze the use of our products, services, or website.


•         + Analyze your visits to our website, social media platforms.


•         + Conduct joint marketing campaigns with other companies and service providers.


•         + Comply with or fulfill legal obligations and regulatory requirements.

    Any individual has the right to opt out of receiving further marketing information from us by unsubscribing from mailing lists, subscriptions, or contacting our Data Administrator. If we contact that individual via email, they may use the unsubscribe function available in the email to notify us. Such requests will be processed within 30 days.

5 - Disclosure of personal data

    We do not disclose personal data to third parties unless required by law, when we have individual consent or are deemed to have consent, or in cases where we cooperate with third parties such as data intermediaries or special subcontractors to support our company operations. Any third party we cooperate with will be contractually bound to keep all information confidential. We may also transfer all data in our possession to a successor related to our business or assets.

6 - Data accuracy

    We will also make reasonable efforts to ensure any personal data we have about you is correct, accurate, and complete. However, this means you must also promptly notify us of any changes to the personal data you initially provided to us. Any non-compliance on your part may result in our inability to provide you with the products and services you have requested.

7 – Access and correction of personal data

    Upon request, we will provide individuals with access to their personal data or other appropriate information about their personal data in accordance with Decree No. 13/2023/ND-CP. Before approving your request, we may need to verify your identity by checking your NRIC or other legal identification documents. Upon request, we will correct errors or omissions in the personal data held or controlled by us in accordance with Decree No. 13/2023/ND-CP. We may charge a fee for access requests as prescribed by Decree No. 13/2023/ND-CP.

    If you discover that the personal data we hold about you is inaccurate, incomplete, misleading, or not up to date, you may request us to correct that data. In cases where we reasonably determine that correction is necessary, we will correct the data as soon as possible or within 30 days from the date we receive your request.

8 – Withdrawal of consent

    If you wish to withdraw consent, you should notify us in advance within a reasonable period. We will inform you of the possible consequences of withdrawing your consent, for example, if we lack your personal contact information, we may not be able to notify you of future services we provide.

Withdrawal requests can be made via email or letter sent to us, or through the 'UNSUB' function on online services.

9 – Use of Cookies

    When you interact with our website or mobile website, we may automatically collect technical data about your device, browsing behavior, and interaction patterns. We collect this data using cookies, server logs, and other similar technologies. If you do not want us to collect such technical data from you, you can change your cookie settings in your web browser at any time. You may choose not to accept cookies by disabling this feature in your web browser. Note that by doing so, you may not be able to use some features and functions in our web applications.

10 - How we protect your personal data

    - We will make reasonable efforts to protect personal data in our possession by establishing reasonable security measures to prevent unauthorized access, collection, use, disclosure, copying, modification, removal, or any similar risks. We have also established reasonable and appropriate organizational measures to maintain the confidentiality and integrity of your personal data and will only share your data with authorized persons on a need-to-know basis.

    - We have established policies to ensure that personal data in our possession will be deleted or anonymized as soon as there is reasonable reason to believe that (i) the purpose for which the personal data was collected is no longer served by retaining that personal data and (ii) retention is no longer necessary for any other legal or business purposes.

11 - Retention of personal data

    We will cease to retain personal data as soon as there is reasonable reason to believe that the purpose for which the personal data was collected is no longer served by retention, and such retention is no longer necessary for any other legal or business purposes. We will properly and safely delete or destroy documents containing your personal data when the retention limit is reached.

12 - Transfer of personal data outside Vietnam

    Usually, we do not transfer your personal data outside Vietnam. We will ensure that any transfer of personal data to a territory outside Vietnam will comply with Decree No. 13/2023/ND-CP to ensure a standard of protection for the transferred personal data equivalent to the protection under Decree No. 13/2023/ND-CP.

13 - Contact us (feedback, access, correction, and withdrawal of your personal data)

    - Provide your feedback on any issues related to your personal data or this Privacy Notice. Withdraw your consent for any collection, use, or disclosure of your personal data or request access and correction of personal data currently held by us, you may contact us at trackasia.vn

    - We take such queries and feedback seriously and will address them diligently and reliably, ensuring confidentiality and handling them within a reasonable period.

14. Location Data

“Background Location Data” refers to location data collected when the app is not actively being used (for example when the screen is off, the app is in the background, or the phone is locked).

What location data we collect

• Precise device location (using GPS, network‑based location, WiFi/cell tower info) when the app is in the foreground (i.e. while the app is visible or being actively used).
• Precise device location while the app is in the background or not actively used, by requesting the Android permission ACCESS_BACKGROUND_LOCATION. This enables the app to continue tracking device location even when the user has switched to another app or locked the screen.

Why we collect background location data

• Real‑time tracking of the device’s location even when the app is not visible to the user, for example to monitor vehicle/fleet movement, route tracking, or geofencing alerts.
• Provide location‑based services/notifications triggered by device movement or entry/exit of geographic zones, even when the app is running in the background. These features cannot be delivered reliably if location is only collected while the app is in the foreground.

How we use location data

• To provide you and/or your organisation with accurate tracking of assets or vehicles over time.
• To trigger alerts or notifications based on the device’s movement or entering/exiting particular geographic areas.
• To maintain a historical log of location data (for example to display past routes or trips).
• We do not use background location data solely for advertising, marketing profiling, or selling the data to third‑parties.

User control & disclosure

• You may disable background location tracking in your device’s settings or revoke the permission ACCESS_BACKGROUND_LOCATION.
• Before the system prompts you to grant background location permission, we display a prominent in‑app disclosure informing you that the app will collect location data while it’s not in use, and explaining why.
• The privacy policy link is available in the app and on the store listing page.

Data retention and sharing

• We retain location data only for as long as necessary to fulfil the tracking and service functions described above.
• We may share your location data with authorised third‑party service providers strictly to enable the core tracking service.
• We do not sell your location history or use it for advertising or profiling beyond the service you subscribed to.

Risk & safeguards

• Background location tracking can consume additional battery power; we implement best practices to limit frequency of updates.
• We protect your location data with appropriate technical and organisational measures.