Privacy & Cookie Policy

INTRODUCTION

Trump International Vietnam is committed to protecting your privacy and personal data.

This Privacy & Cookie Policy explains:

what information we collect;

how and why we collect it;

how we process, use, store, disclose, transfer, protect, delete, destroy, and de-identify it;

how long we keep it;

who we share it with;

how cookies and similar technologies are used;

what rights you may exercise in relation to your personal data.

This Policy applies to personal data processed through the Website and related digital channels operated or made available by Trump International Vietnam, including online enquiry forms, newsletter subscription forms, event registration forms, membership enquiry forms, reservation tools, customer relationship management activities, marketing platforms, analytics tools, advertising technologies, and other Website operation functions.

This Policy is intended to comply with applicable Vietnamese laws on personal data protection, cybersecurity, advertising, consumer protection, e-commerce, and electronic communications, including the Law on Personal Data Protection No. 91/2025/QH15 and Decree No. 356/2025/ND-CP. Where the processing of personal data is also subject to other applicable privacy laws, including the EU General Data Protection Regulation or the UK GDPR, we will comply with such laws to the extent applicable. In the event of any inconsistency between this Policy and mandatory requirements of Vietnamese law, the mandatory requirements of Vietnamese law shall prevail.

DATA CONTROLLER

[Verified full legal entity name and registered address] acts as the Data Controller for personal data it determines the purposes and means of processing through this Website.

Contact: privacy@trumpinternationalvietnam.com

PERSONAL DATA WE COLLECT

We may collect personal data that you provide directly to us, personal data generated through your use of the Website, personal data collected through cookies and similar technologies, and personal data lawfully received from authorized third parties.

The personal data we collect may include:

Identity Information

Full name

Nationality

Date of birth

Contact Information

Email

Telephone

Mailing address

Property Interest Information

Preferred property type

Investment budget

Ownership objectives

Membership Information

Golf membership interest

Club participation

Reservation Information

Event registrations

Hospitality inquiries

Technical Information

IP address

Device information

Browser information

Operating system

Cookie identifiers

Other information about how you interact with the Website and our digital communications

Marketing Information

Subscription preferences

Campaign engagement

Marketing consent records

Cookie preferences

Communication history

Engagement with newsletters, advertisements, event invitations, promotional materials, and project updates.

SENSITIVE PERSONAL DATA

We do not intentionally collect or process sensitive personal data through the Website unless it is necessary for a specific lawful purpose, permitted by applicable law, and supported by an appropriate legal basis, including your explicit consent where required.

Sensitive personal data may include data relating to health, biometric data, genetic characteristics, private life, personal secrets, family secrets, personal location determined by location services, financial or payment information, information on digital account access credentials, images of identity documents, data from tracking behavior or use of services in cyberspace, and other personal data that must be kept confidential or subject to strict security measures under applicable law.

Where we process sensitive personal data, we will inform you that the data to be processed is sensitive personal data, apply stricter access authorization, processing procedures, and security measures, and implement additional safeguards appropriate to the sensitivity and risk of the processing.

LEGAL BASIS

We process personal data where we have a lawful basis to do so under applicable law. Depending on the relevant activity, such basis may include your consent, the performance of an agreement or pre-contractual request with you, compliance with legal obligations, protection of lawful rights and interests in a necessary manner, performance of state authority requests where applicable, or another basis permitted under applicable law.

PURPOSES OF PROCESSING

We process your personal data only for specific, clear, and lawful purposes, and on one or more legal bases permitted under applicable law, as follows:

(a) Processing Based on Contractual Necessity / Pre-Contractual Measures

We may process your personal data where necessary to perform an agreement with you or to take steps at your request prior to entering into an agreement. This includes processing for the purposes of managing customer relationships, responding to enquiries, providing information requested by you, arranging appointments and site visits, managing reservations, handling membership or application processes, facilitating event registrations, and providing customer support services.

Such processing is necessary to enable us to provide services and respond to your requests efficiently and to manage ongoing interactions with you.

(b) Processing for Compliance with Legal and Regulatory Obligations

We may process your personal data where necessary to comply with applicable legal or regulatory obligations. This includes processing for compliance with personal data protection, cybersecurity, tax, accounting, reporting, consumer protection, e-commerce, and advertising laws; responding to lawful requests or orders from competent authorities; maintaining required records; conducting audits; preventing fraud, misuse, and unlawful activities; and enforcing our legal rights.

(c) Processing Based on Legitimate Interests (Where Permitted)

Where permitted by applicable law, we may process personal data based on our legitimate interests in operating, maintaining, securing, and improving the Website and our services. This includes processing for internal administration, system security, fraud prevention, service improvement, analytics (in aggregated or de-identified form where appropriate), and protection of our lawful rights and interests.

(d) Processing Based on Your Consent

We may process your personal data based on your consent for specific purposes where required by applicable law. This includes processing for marketing and promotional activities, such as sending newsletters, project updates, event invitations, and promotional communications; managing marketing preferences; conducting analytics, performance measurement, and user behaviour analysis; personalizing Website content; supporting advertising and remarketing activities; and managing lead generation and marketing campaigns.

Where cookies and similar technologies are used to collect data for analytics, personalization, or advertising purposes, such processing will also be based on your consent where required.

(e) Processing Without Consent in Specific Cases Permitted by Law

In certain circumstances, we may process personal data without your consent where permitted under applicable law. This may include cases necessary to protect life, health, or property in urgent situations; to protect lawful rights and interests; to respond to national security requirements; or other cases as prescribed by law.

AUTOMATED DECISION-MAKING

We do not make solely automated decisions that produce legal or similarly significant effects concerning you.

DIRECT MARKETING

We may send, where permitted by applicable law and your consent preference:

newsletters;

project updates;

launch announcements;

event invitations.

Users may unsubscribe from marketing communications at any time by clicking the unsubscribe link in our emails, following the opt-out instructions in our messages, adjusting your preferences where available, or contacting us directly.

DATA SHARING

We may share information with:

Group Companies

We may share personal data with authorized affiliates, project companies, brand or licensing entities, developers, sales agents, property managers, hospitality operators, golf club operators, event organizers, customer service providers, and other entities involved in the project where such sharing is necessary for the purposes described in this Policy.

Service Providers

We may share personal data with service providers that support Website operation, hosting, cloud computing, cybersecurity, CRM systems, analytics, advertising, marketing, email delivery, customer support, event management, payment processing, document management, data storage, data security, and other operational functions.

Legal Authorities

We may share personal data with professional advisers, auditors, insurers, banks, transaction counterparties, competent authorities, courts, regulators, law enforcement agencies, and other parties where necessary for legal, compliance, audit, risk management, dispute resolution, transaction, or regulatory purposes.

We do not sell or purchase personal data.

CROSS-BORDER DATA TRANSFERS

Your personal data may be transferred to, stored in, accessed from, or processed in jurisdictions outside Vietnam, including where our affiliates, brand or licensing entities, cloud hosting providers, CRM providers, analytics providers, marketing platforms, advertising partners, technical service providers, or other authorized recipients are located outside Vietnam.

Where required we implement:

Standard Contractual Clauses;

GDPR safeguards;

Cross-border transfer requirements under Vietnamese law;

security assessments.

Where required by Vietnamese law, we will prepare and maintain transfer impact assessments and transfer documentation required for cross-border data transfers.

DATA RETENTION

We retain personal data only for as long as reasonably necessary to fulfill the purposes for which it was collected, to comply with applicable legal, accounting, tax, audit, reporting, cybersecurity, consumer protection, e-commerce, advertising, and regulatory obligations, to maintain consent and preference records, to resolve disputes, to enforce our terms, and to protect our lawful rights and interests.

The applicable retention period may vary depending on the type of personal data, the processing purpose, the nature of our relationship with you, mandatory retention requirements, legal limitation periods, and compliance needs. For example only:

Lead Database: 5 years

Marketing Consent Records: 10 years

Customer Service Records: 5 years

Website Analytics: 26 months

Cookie Preferences: 12 months

Legal Records: As required by law

SECURITY

We implement appropriate managerial, technical, and organizational measures to protect personal data against unauthorized access, collection, use, disclosure, modification, loss, destruction, or other unlawful processing. Such measures may include access controls, authentication measures, encryption, de-identification, anonymization where appropriate, audit logs, vulnerability management, system monitoring, backup procedures, incident response procedures, contractual controls with service providers, staff training, internal policies, and periodic review of protection measures.

YOUR PRIVACY RIGHTS

Subject to applicable law, you may have the right to be informed about the processing of your personal data, to consent or refuse consent to processing, to request withdrawal of consent, to view your personal data, to modify or request modification of your personal data, to request provision of personal data, to request deletion of personal data, to request restriction of processing, to object to processing, to lodge complaints, denunciations, lawsuits, and claims for damages, and to request relevant parties to take measures and solutions to protect your personal data.

You also have obligations to protect your own personal data, respect and protect the personal data of others, provide personal data fully and accurately where required by law, contract, or consent, and comply with applicable personal data protection laws.

To exercise your rights, please contact us using the details in this Policy. We may request information necessary to verify your identity and process your request. We may refuse or restrict a request where permitted or required by law, including where continued processing or retention is necessary for legal compliance, dispute resolution, cybersecurity, fraud prevention, protection of lawful rights and interests, or another lawful basis.

GDPR RIGHTS

Where EU or UK GDPR applies, individuals may additionally:

lodge complaints with supervisory authorities;

request transfer mechanisms;

object to direct marketing and profiling where applicable, and withdraw consent without affecting prior lawful processing.

COOKIES POLICY

We use cookies and similar technologies to operate the Website, improve functionality, analyze usage, and support marketing activities.

Where consent is required, we do not activate non-essential cookies before your affirmative choice, and rejecting is as easy as accepting. You may manage or withdraw your cookie preferences at any time through the tools provided on the Website or through your browser settings.

Where tracking technologies are used for analytics or advertising purposes, you will be provided with appropriate choices and controls.

COOKIE CATEGORIES

Strictly Necessary

Website functionality.

Performance Cookies

Analytics and performance monitoring.

Functional Cookies

Preference management.

Advertising Cookies

Remarketing and campaign measurement.

THIRD-PARTY COOKIES, ANALYTICS AND ADVERTISING TOOLS

The Website may use third-party cookies, pixels, tags, embedded content, analytics tools, advertising technologies, CRM tools, marketing automation tools, video hosting tools, social media plug-ins, mapping tools, and similar technologies provided by third-party service providers. These providers may include analytics providers, advertising networks, social media platforms, video platforms, cloud providers, CRM providers, and marketing service providers used from time to time.

Potential providers:

Google Analytics 4

Google Ads

Meta Pixel

LinkedIn Insight Tag

YouTube

Vimeo

Where such third parties independently determine their processing purposes and means, their own terms and privacy notices may apply, and you should review those notices to understand how they process your personal data.

DATA BREACH RESPONSE

We will notify competent authorities and affected individuals of a personal data breach within applicable legal time limits where required.

CHANGES TO THIS POLICY

We may update this Policy periodically.

The latest version will be published on the Website and will take effect upon publication.

CONTACT US

If you have any questions or requests regarding this Policy or your personal data, please contact us at:

Privacy Officer

Trump International Vietnam

Email: privacy@trumpinternationalvietnam.com