Privacy Policy

Last Updated: 03 February 2026

1. Introduction

At NTB Industrial Park (NTB), we are committed to protecting the privacy and security of your personal information in the context of our role as a future-ready industrial park and integrated factory solutions platform. This Privacy Policy outlines how we collect, use, disclose, and safeguard personal data obtained through our website, digital platforms, and interactions with potential tenants, investors, technology partners, and other stakeholders.

NTB provides integrated industrial solutions, including renewable energy infrastructure (such as rooftop solar systems and energy storage), AI-enabled systems, and ready-built green infrastructure. As part of these activities, we ensure that all personal data is processed transparently, lawfully, and securely, in compliance with applicable data protection regulations, including the General Data Protection Regulation (GDPR) where applicable.

This policy applies to all website visitors, prospective tenants, investors, business partners, and international stakeholders engaging with NTB across Vietnam, the European Union, Japan, South Korea, China, and other markets. By accessing or using our services, you acknowledge and agree to the practices described in this policy.

2. Information We Collect

NTB Industrial Park (NTB) collects personal data through two primary channels to support our industrial park operations and advanced factory solution offerings.

Information You Provide Directly

When you engage with NTB through inquiries, registration forms, ESG or energy solution discussions, or tenancy applications, we may collect:

• Identification and contact details (name, job title, company name, email address, telephone number)
• Business-related information such as industry sector, factory scale, energy requirements, ESG or CBAM-related needs, and intended export markets
• Information related to renewable energy integration, smart factory systems, or sustainability objectives, where voluntarily provided

Information Collected Automatically

When you visit our website or digital platforms, we automatically collect certain technical and usage information, including:

• IP address, browser type, device information, and approximate geographic location
• Website interaction data, page views, and usage patterns
• Cookie and tracking data, as detailed in our Cookie Policy

This information helps us optimize our website, improve digital performance, and understand how users engage with NTB’s industrial and sustainability-focused solutions.

3. Purposes Of Data Processing

NTB Industrial Park (NTB) processes personal data solely for legitimate and transparent purposes aligned with our industrial park and factory solution services.

These purposes include:

• Responding to inquiries related to industrial land, ready-built factories, renewable energy systems, AI-enabled infrastructure, and ESG-ready solutions
• Assessing and processing tenancy applications and partnership proposals
• Supporting discussions around energy efficiency, emissions data readiness, and sustainability compliance
• Improving website functionality, performance, and user experience
• Providing relevant updates on NTB’s infrastructure, sustainability initiatives, and service developments, where consent has been obtained
• Fulfilling legal, regulatory, and compliance obligations under Vietnamese law and applicable international regulations, including GDPR

Personal data is never processed for purposes that are incompatible with those stated above without obtaining prior consent.

4. Legal Basis For Processing

NTB Industrial Park (NTB) processes personal data based on the following lawful grounds, as applicable:

• Contractual Necessity: Processing required to evaluate and execute tenancy agreements, service arrangements, or partnership engagements.
• Legitimate Interests: Processing necessary for operating and improving our industrial park, digital platforms, ESG-ready infrastructure offerings, and business communications, provided such interests do not override individual rights.
• Legal Obligations: Processing required to comply with Vietnamese laws, regulatory requirements, and statutory reporting obligations.
• Consent: Processing for marketing communications, newsletters, or non-essential data activities, where explicit consent has been obtained. Consent may be withdrawn at any time.

For individuals located in the European Union, NTB ensures all processing activities comply with Article 6 of the GDPR.

5. Data Sharing Practices

NTB Industrial Park (NTB) does not sell, trade, or commercially exploit personal data. Personal information is shared strictly under controlled, transparent, and lawful circumstances, and only to the extent necessary to support NTB’s legitimate business operations.

NTB may share personal data with carefully selected service providers, such as IT infrastructure partners, customer relationship management (CRM) system providers, and data analytics services, solely for the purpose of operating, maintaining, and improving our digital platforms and business processes. In certain cases, personal data may also be shared with professional advisors or technology partners involved in the delivery of renewable energy solutions, AI-enabled systems, or industrial infrastructure services, provided such sharing is necessary for the requested services and, where required, based on the data subject’s consent.

Additionally, NTB may disclose personal data to competent government authorities or regulatory bodies when such disclosure is required to comply with applicable Vietnamese laws, regulatory obligations, or lawful requests from public authorities.

All third parties receiving personal data from NTB are contractually bound to process such data only in accordance with NTB’s documented instructions and applicable data protection regulations, including the General Data Protection Regulation (GDPR) where relevant. NTB ensures that appropriate confidentiality, security, and data protection safeguards are in place for all data-sharing arrangements.

6. Data Retention Policy

NTB Industrial Park (NTB) retains personal data only for the period necessary to fulfill the purposes outlined in this Privacy Policy, taking into account the nature of the data, the context in which it was collected, and applicable legal and regulatory requirements.

Personal data related to tenancy applications, contractual relationships, and business partnerships is retained for the duration of the relevant business relationship and, where applicable, for an additional period as required under Vietnamese commercial, tax, or regulatory laws. Information collected for marketing communications or general inquiries is retained only for as long as consent remains valid or until such data is no longer relevant to the stated purpose.

Technical, operational, and analytical data collected through NTB’s digital platforms is retained in anonymized or aggregated form wherever feasible, thereby minimizing the identification of individuals while supporting system performance and continuous improvement.

Upon the expiration of applicable retention periods, NTB applies secure deletion and destruction procedures in accordance with recognized industry standards to ensure that personal data is permanently removed and cannot be reconstructed.

7. Data Subject Rights

NTB Industrial Park (NTB) respects and upholds the rights of individuals in relation to their personal data. In accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) where relevant, data subjects are entitled to exercise specific rights to ensure transparency, fairness, and control over how their personal information is processed.

Subject to applicable legal conditions, you may exercise the following rights:

• The right to access personal data held by NTB and to request rectification of inaccurate or incomplete information
• The right to request erasure of personal data (“right to be forgotten”) where the data is no longer necessary for its original purpose or where consent has been withdrawn
• The right to request restriction of processing in certain circumstances, such as while the accuracy or lawful basis of the data is being verified
• The right to object to the processing of personal data, particularly where processing is based on NTB’s legitimate interests
• The right to data portability, allowing you to receive certain personal data in a structured, commonly used, and machine-readable format, where technically feasible
• The right to withdraw consent at any time, without affecting the lawfulness of processing carried out prior to such withdrawal

For individuals located in the European Union, these rights are supplemented by the right to lodge a complaint with a competent supervisory authority in their country of residence, place of work, or place of the alleged infringement, in accordance with GDPR requirements.

Requests to exercise data subject rights may be submitted using the contact details provided in Section 13 of this Privacy Policy. To protect the security of personal data, NTB may require reasonable verification of identity before processing such requests. While NTB endeavors to respond to all requests in a timely manner, certain legal or contractual obligations may limit the scope of actions that can be taken, in which case a clear explanation will be provided.

8. Data Security Measures

NTB Industrial Park (NTB) implements appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. Our security framework is designed to support NTB’s operations as an integrated industrial park and factory solutions platform, including the management of digital systems related to renewable energy infrastructure, AI-enabled platforms, and green industrial facilities.

Technical Safeguards

NTB applies industry-recognized technical safeguards to ensure the confidentiality and integrity of personal data. These measures include:

• The use of encryption technologies to protect data during transmission and, where appropriate, during storage
• Deployment of firewalls, intrusion detection and prevention systems, and continuous monitoring tools to identify and mitigate security threats
• Secure system architecture with access controls, authentication mechanisms, and role-based permissions to restrict data access to authorized users only

Organizational Controls

In addition to technical measures, NTB enforces strict internal governance and organizational controls to manage data securely throughout its lifecycle. These controls include:

• Clearly defined internal policies governing data access, processing, and handling on a need-to-know basis
• Regular internal reviews and audits to ensure compliance with data protection obligations
• Confidentiality and data protection obligations incorporated into employment agreements and contracts with third-party service providers

Staff Training & Awareness

NTB recognizes that data security is supported by informed and responsible personnel. Accordingly, we implement ongoing training and awareness initiatives, including:

• Periodic training programs for employees on data protection principles, secure data handling, and privacy obligations
• Awareness initiatives to help staff recognize cybersecurity risks such as phishing, social engineering, and unauthorized access attempts
• Clear internal procedures for reporting suspected data protection or security incidents

Incident Response Preparedness

NTB maintains an incident response framework designed to ensure timely and effective action in the event of a data breach or security incident. This framework includes:

• Documented procedures for incident detection, containment, investigation, and remediation
• Internal escalation protocols to ensure prompt decision-making and coordination
• Notification processes aligned with applicable legal requirements, including GDPR breach notification obligations where relevant

While no security system can guarantee absolute protection, NTB continuously reviews and enhances its technical and organizational measures to maintain a level of security appropriate to the risks associated with personal data processing.

9. International Data Transfers

NTB Industrial Park (NTB) primarily processes and stores personal data within the territory of Vietnam. However, in certain limited circumstances, cross-border transfers of personal data may be necessary, particularly when engaging with international investors, tenants, technology partners, or service providers, or when responding to inquiries originating from overseas markets.

Where personal data is transferred outside Vietnam, including to jurisdictions such as the European Union, Japan, South Korea, China, or other countries, NTB ensures that such transfers are conducted lawfully and with appropriate safeguards in place to maintain an adequate level of data protection. Cross-border transfers are carried out only when necessary for legitimate business purposes and in compliance with applicable Vietnamese regulations and international data protection standards, including the General Data Protection Regulation (GDPR) where applicable.

To safeguard personal data during international transfers, NTB implements a combination of legal, technical, and organizational measures, which may include:

• The use of legally binding data transfer agreements incorporating Standard Contractual Clauses (SCCs) or equivalent safeguards recognized under applicable laws
• The application of encryption, access controls, and other technical security measures to protect data during transmission and storage
• The performance of transfer risk or impact assessments, where required, to evaluate the data protection standards of recipient jurisdictions and organizations

NTB regularly reviews its cross-border data transfer practices to ensure ongoing compliance with evolving legal requirements and to maintain the confidentiality, integrity, and security of personal data transferred internationally.

10. Cookies And Tracking Technologies

NTB's website uses cookies and tracking technologies to improve user experience:

Purpose Of Usage:

• Enhancing website functionality and performance
• Analyzing visitor traffic patterns
• Remembering user preferences and settings
• Supporting our marketing optimization efforts

Policy Reference:

• Full details available in our dedicated Cookie Policy
• Includes complete list of cookies used
• Specifies their duration and specific functions

Opt-Out Options:

• Browser settings control (accessible through privacy/security tabs)
• Third-party tool for cookie preference management

Note: Essential cookies cannot be disabled as they are required for basic site operations

11. Third-Party Links Disclaimer

Our website may contain links to external websites operated by third parties for your convenience and reference. These links are provided solely as additional resources that may be relevant to your business needs. NTB Industrial Park does not endorse, control, or assume responsibility for the content, privacy practices, or operational standards of any third-party websites. When you choose to access these external sites, you do so at your own discretion and risk.

We strongly recommend reviewing the Privacy policies and Terms of Use of any Third-party websites before engaging with them or providing any personal information.

12. Policy Updates

NTB Industrial Park may update this Privacy Policy from time to time to reflect changes in business operations, technological developments, legal or regulatory requirements, or the scope of services provided, including digital systems, AI-enabled solutions, renewable energy infrastructure, and sustainability initiatives. Where material changes affect the collection, use, or protection of personal data, NTB will take reasonable steps to inform users through appropriate channels. Minor updates may be implemented without prior notice and will be reflected in the revised policy.

The effective date displayed at the beginning of this policy will be revised accordingly with each update. We encourage all users to regularly review this policy to stay informed about how we protect your information. Your continued use of our services following any changes constitutes acceptance of the updated terms.