Privacy Policy

1. Information We Collect

1.1 Information You Provide Directly

When you engage with Afinest Partners — whether through our website, contact forms, consultation requests, or service agreements — we may collect the following categories of personal information:

• Full name, job title, and company affiliation
• Business and personal contact details (email address, phone number, mailing address)
• Information submitted via consultation request forms or inquiry submissions
• Financial and corporate information provided in the context of advisory engagements
• Correspondence, notes, and communications exchanged with our advisory team

1.2 Information Collected Automatically

When you access our website or platforms, we automatically collect certain technical data, including:

• IP address, browser type, operating system, and device identifiers
• Pages visited, time spent on pages, referral URLs, and click-stream data
• Session cookies and analytics identifiers
• Approximate geographic location derived from IP address

1.3 Information from Third Parties

We may receive information about you from business partners, referral sources, publicly available corporate registries, and professional directories, solely for the purpose of evaluating and delivering our advisory services.

2. How We Use Your Information

Afinest Partners uses collected information exclusively for legitimate business purposes, including:

• Delivering, managing, and improving our consulting and advisory services
• Responding to inquiries, scheduling consultations, and maintaining client communications
• Conducting due diligence, market research, and strategic analysis on behalf of clients
• Preparing proposals, engagement letters, reports, and legal documents
• Sending relevant industry updates, regulatory alerts, and service announcements (with your consent)
• Complying with applicable Vietnamese law and international regulatory requirements
• Protecting the rights, property, and security of Afinest Partners and its clients
• Analysing website performance and improving user experience

3. Legal Basis for Processing

Where applicable under the Law on Cybersecurity (Vietnam, 2018), Decree No. 13/2023/ND-CP on Personal Data Protection, and international frameworks including the GDPR, we process personal data on the following legal bases:

• Contractual necessity — processing required to perform our advisory services under an engagement agreement
• Legitimate interests — business development, security, fraud prevention, and service improvement
• Consent — for marketing communications and non-essential cookies, where you have given explicit consent
• Legal obligation — compliance with Vietnamese law, tax obligations, and regulatory requirements

4. Disclosure of Your Information

We maintain strict confidentiality over all client information. We may disclose your personal data only in the following limited circumstances:

• Service providers — trusted third-party vendors (IT infrastructure, cloud hosting, legal counsel) bound by confidentiality agreements
• Professional advisors — lawyers, auditors, and consultants engaged in connection with our services
• Regulatory authorities — government bodies, courts, or law enforcement when required by applicable law or legal process
• Business transfers — in connection with a merger, acquisition, or sale of assets, subject to equivalent confidentiality obligations
• With your consent — any other disclosure made only with your explicit prior agreement

5. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, and in accordance with our legal and regulatory obligations:

• Client engagement records are retained for a minimum of five (5) years following the conclusion of an engagement, in compliance with Vietnamese commercial and tax law
• Website inquiry and contact form data is retained for twenty-four (24) months from the date of submission
• Marketing communication preferences and consent records are retained until withdrawal of consent plus twelve (12) months
• Technical logs and analytics data are retained for twelve (12) months

Upon expiry of the applicable retention period, data is securely deleted or anonymised.

6. Data Security

Afinest Partners implements industry-standard technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS/SSL encryption for all data transmitted via our website and platforms
• Access controls and role-based permissions limiting data access to authorised personnel only
• Regular security assessments and vulnerability monitoring
• Confidentiality obligations imposed on all staff and third-party processors
• Secure data storage on servers located within compliant jurisdictions

While we employ rigorous safeguards, no method of electronic transmission or storage is completely secure. We encourage clients to exercise appropriate caution when sharing sensitive information digitally.

7. International Data Transfers

As a firm serving clients across multiple jurisdictions, it may be necessary to transfer your personal data to countries outside Vietnam. Where such transfers occur, we ensure that appropriate safeguards are in place, including contractual clauses, equivalent data protection standards, and compliance with Vietnamese cross-border data transfer regulations under Decree 13/2023/ND-CP.

8. Your Rights & Choices

Subject to applicable law, you have the following rights with respect to your personal data:

• Right of access — to request a copy of the personal data we hold about you
• Right to rectification — to request correction of inaccurate or incomplete data
• Right to erasure — to request deletion of your data where there is no overriding legal basis for retention
• Right to restriction — to request that we limit processing of your data in certain circumstances
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object — to object to processing based on legitimate interests or for direct marketing purposes
• Right to withdraw consent — to withdraw previously given consent at any time, without affecting prior processing

To exercise any of these rights, please contact our Data Protection Officer at info@afinestpartners.com. We will respond within thirty (30) days of receiving a verified request.

9. Cookies & Tracking Technologies

Our website uses cookies and similar technologies to enhance functionality and analyse usage patterns. We use the following categories of cookies:

• Strictly necessary cookies — essential for the website to function and cannot be disabled
• Analytics cookies — used to understand how visitors interact with our website (e.g., Google Analytics), subject to your consent
• Preference cookies — used to remember your settings and preferences across sessions

You may manage your cookie preferences through your browser settings at any time. Disabling certain cookies may affect the functionality of our website.

10. Third-Party Links

Our website and platforms may contain links to third-party websites, including our proprietary platforms SMARTKEY.IO.VN, MASMART.IO.VN, and AGRICONNECT. Each of these platforms operates under its own privacy policy. We encourage you to review the privacy practices of any third-party site before providing personal information. Afinest Partners accepts no responsibility for the privacy practices of external websites.

11. Children's Privacy

Our services are directed exclusively at businesses and professionals. We do not knowingly collect personal information from individuals under the age of eighteen (18). If we become aware that we have inadvertently collected data from a minor, we will take prompt steps to delete such information from our records.

12. Changes to This Policy

Afinest Partners reserves the right to update this Privacy Policy at any time to reflect changes in our practices, applicable law, or regulatory requirements. Material changes will be communicated via a prominent notice on our website and, where appropriate, by direct notification to affected clients. The "Last Updated" date at the top of this page indicates when the most recent revision was made. Continued use of our services following any update constitutes acceptance of the revised policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us through any of the following channels:

You also have the right to lodge a complaint with the relevant data protection authority in your jurisdiction if you believe your rights have not been adequately addressed.