Privacy Policy

Vietnam Holding Limited or any third party service provider, functionary, or agent appointed by the company acting on its behalf (together the "VNH", "we", "us", "our") are committed to protecting your personal data and are required, by Data Protection Legislation (as defined below), to provide individuals with certain information about how we use your personal information.

This privacy policy ("Privacy Policy") explains what information we collect from you or you provide to us, how we use it and with whom we share that information. This Privacy Policy also sets out your rights and who you can contact for more information.

In this Privacy Policy:

  • your information is sometimes called "personal data";
  • we may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as "processing" such personal data; and
  • the term "Data Protection Legislation" means the Data Protection (Bailiwick of Guernsey) Law 2017, the EU General Data Protection Regulation 2016/679 (to the extent applicable); together with all other applicable legislation relating to privacy or data protection.

For the purposes of Data Protection Legislation - VNH is the controller.

1What information we collect about you

VNH may collect, record and use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with Data Protection Legislation and as set out in this Privacy Policy.

The personal data we, collect and process may include:

  • information obtained from identification documentation (including your name, contact details, nationality and national identify numbers (where applicable));
  • your professional title and occupation;
  • your age and marital status;
  • financial information, tax status, account details and evidence of ownership of financial assets;
  • personal identifiers such as your social security number, national insurance number, tax file number, IP address or our internal electronic identifiers;
  • information which we or our service providers need to conduct ‘know your client’ checks such as details relating to your passport and credit history; and
  • other information you provide in the course of your dealings with us or which they each require to provide you with products and services.

In certain circumstances, we also collect and process what are known as 'special categories' of personal data (as defined by Data Protection Legislation). Money laundering, sanctions, financial crime and fraud prevention checks sometimes result in VNH obtaining information about actual or alleged criminal convictions and offences.

You are not obliged to provide us with your personal data where it is requested but we may be unable to provide certain products and services or proceed with your business relationship with VNH if you do not do so.

2 How we collect your information

The information we collect comes from:

  • application forms or other materials you or your authorised representative submits to us during the course of your relationship with VNH;
  • your or your authorised representative's interactions with VNH, transactions and use of our products and services (including the use of our website);
  • your or your authorised representative's business dealings with VNH, including via email, telephone or as stated in contracts with you;
  • depending on the products or services you or your authorised representative requires, third parties (including for credit and money laundering checks, among other things); and
  • recording and monitoring tools that they use for compliance or security purposes (e.g. recording of telephone calls, monitoring emails, etc.).

3How we use your information

Our primary purpose in collecting your personal information is facilitate the holding of shares in Company, the management and administration of your holdings in VNH and any related administration on an on-going basis.

Additionally, we use your information for the following specific purposes:

  • to process transactions and to improve the quality of the service that we provide to you;
  • to disclose information to other third parties such as service providers of VNH, auditors, regulatory authorities and technology providers (as set out in more detail below)
  • to communicate with you as necessary in connection with the proper running of VNH;
  • to update and maintain records and carry out fee calculations;
  • to monitor and record calls and electronic communications;
  • in connection with VNH’s internal management and reporting;
  • to report regulatory and tax related information to regulatory and tax authorities in order to comply with a legal obligation, including any obligation arising under legislation implementing FATCA and the CRS;
  • permit, administer and record your investment in VNH;
  • verifying the identity of the prospective investor to comply with statutory and regulatory requirements in relation to anti-money laundering procedures;
  • in order to carry out anti-money laundering checks and related actions which are necessary to comply with legal obligations, in relation to, the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis;
  • for prudential and risk management purposes;
  • to provide you with any products and services that you request from us; and
  • other reasons compatible with the primary purpose.

If is necessary to use it for another reason and that reason is compatible with the original purpose.

4Legal grounds for using your personal information

Data Protection Legislation permits us to process your personal data in the way that it does because the processing is:

  • necessary for the purposes of the legitimate interests that we pursue, which are to run and administer VNH, to discharge our legal obligations, to store and disclose information where necessary and to evaluate, develop and improve our services; or
  • necessary for the performance of a contract with you; or
  • necessary in order to comply with a legal obligation to which we are subject.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that personal data; (ii) you have made the personal data manifestly public; or (iii) the processing is necessary for the establishment, exercise or defence of legal claims.

5Providing your information to third parties

The following categories of recipients may receive your personal information and process it for the purposes outlined in this Privacy Policy:

  • third parties such as service providers of VNH, auditors, regulatory authorities and technology providers, agents, contractors, service providers or related companies (including payment processors) if this is necessary to administer your investment in VNH, respond to your enquiries or for any other related purposes;
  • any regulatory, supervisory or governmental authorities to the extent we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud;
  • tax authorities.

VNH does not undertake marketing activities for third parties, nor does it provide information to third parties for their own marketing purposes.

6Transferring data outside of the EEA

Personal data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") or to countries not regarded by the European Commission as providing an adequate level of data protection. When we, or our permitted third parties, transfer personal information in this manner will ensure that the transfer is subject to appropriate safeguards in accordance with Data Protection Legislation.

7Automated processing

We do not carry out automated decision-making or profiling.

8 Your rights

At any time, you have the right:

  • to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
  • to request access to or a copy of any personal data which we hold about you;
  • to rectification of your personal data, if you consider that it is inaccurate;
  • to ask us to delete your personal data, if you consider that we do not have the right to hold it;
  • to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
  • to restrict processing of your personal data;
  • to data portability (moving some of your personal data elsewhere) in certain circumstances;
  • to object to your personal data being processed in certain circumstances; and
  • not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.

9How long we keep your information

We will only keep the information we collect about you for as long as required for the purposes set out in this Privacy Policy or as required to comply with any legal obligations to which we are subject being the longest of the following periods:

  • a minimum of six years;
  • as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with VNH;
  • the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations;
  • any retention period that is required by law; or
  • the end of the period in which litigation or investigations might arise in respect of an investment in VNH.

This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

10How we protect your information

We ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect your personal details from unauthorised access.

11Changes to Privacy Policy

This privacy notice may be amended from time to time without notice, in which case the date of this privacy notice will be revised. If our privacy policy changes in any way, we will place an updated version on this page.

Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.


This Privacy Policy is for your information and should not be used as the basis for any decision to purchase or redeem investments in VNH. The views and information expressed in this policy do not constitute and may not be relied upon as constituting any form of investment advice or inducement to invest, and prospective investors must obtain appropriate independent professional advice before making investment decisions.

VNH’s website may contain may contain hyperlinks to external websites. VNH is not responsible for and accepts no liability in relation to these websites or their contents. You should read any applicable privacy policy on any such website.

13Cookies Policy

a. Our use of cookies
Vietnam Holding Limited or any third party service provider, functionary, or agent appointed by the company acting on its behalf (together the "VNH", "we", "us", "our") set and access cookies and similar technology on your device to obtain information about how you access and use of our website (the “Website”).

This helps us to provide you with a good experience and allows us to improve the Website. Unless you have adjusted your browser settings so that it will refuse cookies, the Website will set cookies when you load and navigate them.

If you have any questions about this Cookies Policy, please email

b. What are cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a Website. Cookies are then sent back to the originating website during your browsing session or on each subsequent visit, or to another website that recognises that cookie.

The cookies we set do lots of different jobs, like help us to improve the Website and deliver a better and more personalised service, remember your preferences, and generally improve the user experience. You can find more information about cookies at

c. What we use cookies for?
We only collect information we feel is essential for you to use our Website efficiently and to improve services for you, for example:

  • for technical purposes essential to the effective operation of the Website;
  • Enabling a service to recognise your device so you don’t have to give the same information several times during one task;
  • measuring how many people are using our Website, to ensure there is enough capacity for our Website to operate at a reasonable speed;
  • completion and support of the current activity being undertaken by the user, for example previously viewed pages;
  • Website and system administration, for example, tracking the number of website users for marketing purposes;
  • Remembering pages viewed.

d. Cookies categories
We use the following types of cookies: [VNH to confirm which cookies it will plant and SH to provide corresponding advice re consent]

  • Strictly necessary cookies – these cookies are essential in order to enable you to move around a Website and use its features and enable services you have specifically asked for. Consent is not generally required for these cookies.
  • Performance cookies – these cookies collect information about how visitors use a Website (for example, by recording which pages or features visitors use most often (usually on an anonymous basis)).
  • Functionality cookies - these cookies allow a Website to remember the choices a user makes, such as a username or language preference.
  • Targeting or advertising cookies - these cookies collect information about a user's browsing habits and are usually placed by advertising networks with the Website operator’s permission.

Cookies can also be categorised in accordance with how long they are saved on your device: "session cookies" are short-term cookies that are only saved on the device's memory for the duration of a user's visit to the Website, whereas "persistent cookies" remain saved in the device's memory for a set period of time, even after the browser session has ended.

e. Refusing or restricting cookies
Where we require consent to plant cookies, you may refuse to accept cookies, when you first visit the Website by declining to provide your consent or if after you have provided such consent or if we do not require your consent - by activating the setting on your browser which allows you to refuse the setting of cookies.

The "Help" or "Internet Settings" functions within your browser should tell you how. Alternatively, you may wish to visit which contains detailed information on cookies and how to delete, restrict or block them on a wide variety of browsers

Please be aware that if you select to refuse or restrict cookies you may be unable to access certain parts of the Website.

f. Changes to this Policy
We may amend this Cookies Policy at any time by posting the amended terms on the Website. All amended terms will automatically take effect immediately on posting. Please check this Cookies Policy periodically to inform yourself of any changes. If you do not accept the changes made to this Cookies Policy, you should immediately stop using the Website.


Questions, comments and requests regarding this Privacy Policy are welcomed and should be marked for the attention of Craig Martin, Chairman, Dynam Capital

You may also use these contact details if you wish to make a complaint to us relating to your privacy.

If you have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Office of the Data Protection Authority, which regulates and supervises the use of personal data in Guernsey.

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