Privacy Policy

SANKEN ELECTRONICS TECHNOLOGY VIETNAM COMPANY LIMITED ("we", "us", or "our") operates the An Vay mobile application and related loan services. We are committed to protecting your privacy and handling personal information in a transparent, lawful, and secure manner. This Privacy Policy describes the categories of information we may collect, the purposes for which we use it, how we store and safeguard it, the limited circumstances in which it may be disclosed, and the rights available to you under applicable privacy and data protection laws in Vietnam. Please read this policy carefully before using An Vay so that you understand how your information is processed throughout your relationship with us.

We follow the principles of data minimization and purpose limitation: we collect only the information that is reasonably necessary to provide, operate, improve, and secure our loan services, including account registration, identity verification (KYC), credit assessment, risk control, disbursement, repayment, and customer support. Personal data is transmitted and stored using industry-standard encryption and access controls. We do not sell your personal information to any third party, and we do not engage in any form of personal data trading.

By downloading, accessing, or using An Vay, creating an account, or submitting a loan application, you acknowledge that you have read this Privacy Policy and agree to its terms. If you do not agree with our practices, please discontinue use of the application and our services. You may contact us at any time using the details in the "Contact Us" section if you have questions about this policy or how we handle your personal information.

To operate An Vay safely and provide loan-related services, we may ask you to grant certain device permissions and to provide the information needed for account security, identity verification, credit assessment, and risk control. Depending on the features you use and the stage of your application, we may request access to the categories of information described below. We will explain the relevant purpose at the time of the request where practicable, and you can manage or withdraw permissions later in your device settings. The details of each category are as follows:

1.1 SMS

We may request access to text messages on your device to identify information related to financial activity—such as bank transaction notifications, loan-related messages, payment reminders, and mobile payment records—for credit assessment, risk management, and fraud prevention. We only use message information that is relevant to financial activities. The data we process may include the sender’s phone number, the date the message was sent, and the message content. We do not use private messages unrelated to finance for these purposes. All such data is protected by encryption during transmission and storage.

1.2 Device Information

We collect necessary device information, including device model, application version, and related device identifiers. This information helps us improve device compatibility, detect devices that show unusual or abnormal signs, maintain system security, and protect your account. Device data is used for service stability, risk control, and security purposes. It is encrypted during both transmission and storage.

1.3 Approximate Location

We may collect approximate location information about your device. This information helps us detect potential fraud risks, reduce risks related to your account, and support overall data and account security. Approximate location is used for risk control and security purposes, not for continuous tracking of your precise movements. Location information is encrypted during both transmission and storage. You may disable this permission at any time in your device settings.

1.4 Camera

We may request access to your camera to capture images of your identity documents and to perform facial recognition. This information is used to verify your identity and to help prevent identity theft and fraud during account registration and loan application. The camera is used only when you actively take part in these verification steps. Related images are encrypted during transmission and storage, and are used solely for identity verification and security checks.

1.5 Installed Applications List

We may request access to information about applications installed on your device. The data collected may include the application name, version number, whether the application is a system application, the initial installation date, and the most recent update date. This information is used to support credit assessment, identify behavioural risks, and prevent fraud, thereby helping protect your account and funds. It is not used for unrelated advertising or marketing purposes. All such data is transmitted and stored with encryption.

1.6 Personal Information You Provide Directly

During the loan application process, you may be asked to provide personal information that we use for identity verification, credit assessment, loan approval, and account management. This generally includes:

• Identity and account details: mobile number, full name, and national ID number — to create your account, contact you about your application, and complete KYC identity checks
• Profile and financial background: residential address, education level, employment type, marital status, and income — to understand your application profile, evaluate repayment capacity, and support credit decisioning
• Payment account information: account details — to disburse approved loan funds and process repayments

All the information above is used only for the stated purposes, securely uploaded to our servers via encryption, and protected by industry-standard security measures.

We use your personal information solely for the purposes outlined below. We collect only the minimum data necessary and process it in accordance with applicable privacy laws in Vietnam.

2.1 Specific Processing Purposes

Depending on how you use An Vay, we may process your information for the following purposes:

• Identity Verification and KYC: To confirm that you are who you claim to be through ID documents, facial recognition, and related checks, and to meet regulatory KYC requirements
• Credit Assessment: To assess your credit standing and determine whether you qualify for a loan, based on the information you provide and the information we obtain with your authorisation
• Risk Control and Fraud Prevention: To identify unusual activity, reduce fraudulent applications, and protect your account and our platform
• Account Registration and Management: To set up your An Vay account, keep your profile up to date, and manage the status of your loan applications
• Loan Disbursement and Repayment: To transfer approved funds to your designated account and manage repayment schedules and records
• Legal Compliance: To meet obligations under applicable laws, regulations, court orders, or lawful requests from authorities
• Customer Support: To respond to your questions, handle complaints, and provide assistance with account or application issues
• Service Improvement: To diagnose technical problems, understand product usage, and improve the stability and usability of An Vay

2.2 Automated Decision-Making and Data Minimization

We may use automated processes, including algorithms and credit scoring models, to assess loan eligibility, determine loan amounts and terms, and help detect potentially fraudulent applications. These tools help us review applications more efficiently. If you disagree with an automated decision, you may request human review by contacting us through the details in the "Contact Us" section.

We also follow data minimization: we only collect and process personal information that is necessary, adequate but not excessive, and kept reasonably accurate for the purposes described above. We will not use your personal information for purposes other than those disclosed in this Privacy Policy without your consent, unless required by law.

Protecting the personal information you provide through An Vay is an important part of our operations. We apply industry-standard technical and organisational measures designed to reduce the risk of unauthorised access, loss, misuse, or alteration of your data while it is being transmitted to our systems and while it is stored on our servers.

In particular, we use the following safeguards:

• Transmission Encryption: When your information is sent from your device to our servers, it is protected with encryption protocols so that it is less likely to be intercepted or tampered with in transit.
• Storage Encryption: Once received, your personal information is kept on controlled secure servers and protected with strong encryption methods appropriate to the sensitivity of the data.
• Access Control: Access to personal information is limited to authorised personnel who need it to perform their duties, such as supporting your account or carrying out risk and compliance checks. Access activities are logged to help us monitor and review how data is handled.

How long we keep your information, and how we delete or anonymise it when it is no longer needed, is explained in the "Data Retention and Deletion" section below.

Your personal information is stored on our secure servers and is handled under controlled internal processes. As a general rule, we do not make your personal information available to unrelated third parties. Disclosure will only occur where it is necessary for the limited reasons set out below, and only to the extent reasonably required for that purpose.

We may disclose personal information in the following circumstances:

• Legal Requirements: When we are required to do so by applicable law, regulation, court order, or a lawful request from a government authority or regulatory body. In such cases, we aim to disclose only the information that is necessary to meet the legal obligation.
• Security Purposes: When disclosure is necessary to detect, investigate, or prevent fraud, identity theft, unauthorised access, illegal activities, or other behaviour that may harm you, other users, or the integrity of the An Vay platform.

We do not sell your personal information, and we do not engage in any form of personal data trading. Where disclosure is required, we take reasonable steps to ensure that the information is handled carefully and used only for the purpose for which it was disclosed.

We retain personal information only for as long as it is reasonably needed to provide An Vay services, fulfil the purposes described in this Privacy Policy, or meet legal and regulatory requirements. When information is no longer needed, we delete or anonymise it in a secure manner.

In general, we apply the following retention approach:

• Active Accounts: We keep your personal information while your account remains active, or for as long as we still need it to operate your account, process loan applications, manage disbursement and repayment, and provide customer support.
• Closed Accounts: After your account is closed, we will delete or anonymise your personal information within 30 days, unless a longer retention period is required by applicable law or needed to resolve outstanding obligations, disputes, or investigations.
• Legal and Compliance Records: Certain records may be retained for a longer period where this is necessary for legal, regulatory, audit, risk-control, or dispute-related purposes.

You may also request deletion of your personal information in accordance with the rights described in the "Your Privacy Rights" section. We will review your request and, where applicable, delete or anonymise the relevant data, except where we are legally required or permitted to retain it. After deletion or anonymisation, the information will no longer be used to identify you in the ordinary course of our operations.

Subject to applicable privacy and data protection laws in Vietnam, you have certain rights in relation to the personal information we hold about you. These rights help you understand how your data is used and allow you to request corrections or other actions where appropriate.

Depending on the circumstances and applicable law, your rights may include:

• Right of Access: To ask whether we hold personal information about you, and to request details about the categories of information held, the purposes for which it is processed, and the parties to whom it may have been disclosed.
• Right to Rectification: To request that we correct personal information that is inaccurate, incomplete, or outdated, so that your account and application records remain reliable.
• Right to Erasure: To request deletion of your personal information in certain circumstances, for example where the information is no longer necessary for the purposes for which it was collected, or where continued retention is not required by law.
• Right to Object: To object to certain processing of your personal information based on your particular situation, where such a right is available under applicable law.

Please note that limiting or withdrawing certain device permissions, or requesting restrictions on processing, may affect the normal functioning of An Vay features, including identity verification and the loan application process. We will explain any material impact where practicable.

To exercise any of these rights, please submit a request using the contact details in the "Contact Us" section. To help us verify and handle your request efficiently, please include your registered mobile number and a clear description of what you are asking us to do. We will respond within the timeframes required by applicable law. If we are unable to fulfil a request in full, we will explain the reason where we are permitted to do so.

If you believe your privacy rights have been violated, you also have the right to lodge a complaint with the relevant data protection supervisory authority.

You may view this Privacy Policy at any time in the An Vay app by opening Settings and selecting Privacy Policy. We may update this policy from time to time to reflect changes in our practices or legal requirements. When we make material changes, we will provide notice in the app (for example, through an in-app notification or pop-up) and update the "Last Update Time" shown at the top of this page. This Privacy Policy is effective as of October 2026. Your continued use of An Vay after an update means you accept the revised terms.

An Vay is a financial service application intended only for users who are 18 years of age or older. We do not knowingly market to, solicit, or collect personal information from children under 18. Parents or guardians who believe that a minor may have provided personal information to us should contact us promptly using the details in the "Contact Us" section.

If we become aware that we have collected personal information from a child under 18 without appropriate parental or guardian consent, we will take reasonable steps to delete or otherwise remove that information from our systems as soon as practicable, unless we are required by law to retain it for a limited period. We may also suspend or close any related account to prevent further unauthorised use of the service.

By using An Vay, you confirm that you meet the applicable age requirement. If you do not meet this requirement, please do not use the application or submit personal information through it.

If you have any questions about this Privacy Policy, wish to exercise your privacy rights, or need help with how your personal information is handled in An Vay, please contact us. We will review your request and respond within a reasonable period in accordance with applicable law. For faster handling, please include your registered mobile number and a clear description of your request when you write to us.