PRIVACY POLICY

Effective Date: This Privacy Policy was last updated on January 01, 2024.
STEEL Sai Gon Joint Stocks Company and its subsidiaries operating under the STEEL brand (collectively, “STEEL” , “we” , “us” , or “our”) respect your privacy and use your personal information in an effort to fulfil our commitment to offering and providing an exceptional, customised member experience. This Privacy Policy (“Privacy Policy”) describes the privacy practices of STEEL, including the types of personal information we obtain, how we use this personal information, with whom we share it and the choices available regarding our use of the information. This Privacy Policy also describes the measures we take to safeguard the personal information and how you can contact us about our privacy policies.
This Privacy Policy applies to the personal information we obtain when you interact with STEEL, including but not limited to when they visit and use our STEEL-branded locations (our “Clubs”), use http://www.steelsaigon.com,http://www.steelsaigon.com.vn, http://www.steelsaigon.vn and any other websites, mobile apps or online services or platforms of STEEL on which this Privacy Policy is included or linked to (collectively, the “Sites”), apply for a job with us or otherwise connect with us.
This Privacy Policy does not apply to STEEL products and services that have separate privacy policies.
  1. Information We Collect
  2. How We Use Your Information
  3. How We Share Your Information
  4. Your Communication Preference
  5. Text Messages
  6. Third-party Sites and Connected Accounts
  7. How We Protect Personal Information
  8. Retention of Personal Information
  9. Intended for Use by Adults
  10. Updates to Our Privacy Policy
  11. How To Contact Us
  12. Cookies Policy

INFORMATION WE COLLECT

The types of personal information we collect include:
  1. Contact information, such as name, email and postal address and phone number.
  2. Professional information, such as job title and employer details.
  3. Login credentials (e.g. username and password).
  4. Payment and financial information, such as your credit/debit card number, expiration date and security code, bank account number, and billing address.
  5. Demographic information you provide when you visit or become a member of a STEEL club, such as date of birth, age, and gender identity or expression.
  6. Information and data regarding your fitness, health, nutrition, activities, biological characteristics, and training goals, programs and progress.
  7. COVID-19 screening information, such as health declarations and vaccination status.
  8. Membership and usage information, such as membership ID, the Clubs you visit and the times you check in, workouts you log, classes you book, information provided when you purchase or schedule training sessions and recovery treatments, and transaction history.
  9. Personal preferences such as favourite clubs, choice of F&B, clothes size, classes and coaches.
  10. Account information if you establish an online account with us, such as login credentials (e.g., username and password).
  11. Images and videos, including photographs and CCTV video footage.
  12. The geolocation of your device if you consent to the collection of this data.
  13. Biometric information such as facial geometry scans or other facial recognition information.
  14. Travel information in connection with STEEL Retreat such as travel itineraries, flight details, visa and travel insurance information, nationality, dietary restrictions, and other information relating to quoting and booking a travel service (e.g., destinations, countries and products you are interested in).
  15. Information in connection with applying for a job at STEEL such as employer and employment history, education, job function, salary, professional certifications and other resume information.
  16. Social media handles, content and other information that you post to our social media pages or tag us on your social media pages, and information we obtain from third-party social media services (e.g., Facebook) if you choose to link to, or create or log in to your STEEL online account through, these services.
  17. Information from third-party fitness devices, apps or services (e.g., Apple Health) or from our affiliates’ or third-party partners’ sites, apps, products, services or offerings (the foregoing, collectively “Connected Accounts”), if you choose to connect any of the foregoing to your STEEL account or our Sites, or if you chose to use your STEEL account to log into or validate your account with any Connected Account.
  18. Other Information you provide to us, including through emails and other communications, surveys, information or content transmitted or uploaded through your STEEL account (such as posts to message boards), and interactions with STEEL and its personnel, or information when you enter any sweepstakes, contests or promotions we may offer.
In many cases, we will collect the personal information described above directly from you. In some cases, however, we will collect the information from other sources, such as:
  1. Business partners: we may obtain your information from other businesses with which we partner to provide you with products, services or offers we believe may be of interest to you, including our on-property partners such as cafes and through any Connected Accounts.
  2. Friends and family: we may obtain your information from your friends and family, such as when they refer to you our products, services or other offers.
  3. Other sources: we may obtain information from other sources such as publicly available databases, joint marketing partners, social media platforms, consumer data resellers, online advertising companies, and vendors who provide services on our behalf.

INFORMATION WE OBTAIN BY AUTOMATED MEANS

When you interact with our Sites, or when you connect to our Wi-Fi network at one of our Clubs, we obtain certain information by automated means, such as cookies, web server logs, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.We use these automated technologies to collect information about your equipment, devices, internet connection, browsing actions, and usage patterns. The information we obtain in this manner may include your IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, browsing history, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Sites. We may also obtain information about how you interact with the Sites, such as features and pages you visit, search queries, and download errors. These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with our products and services; (3) tailor the products and services around your preferences; (4) measure the usability of our products and services and the effectiveness of our communications; and (5) otherwise manage and enhance our products and services.
Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Sites. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.Information about our cookie practices and how to change your cookie settings is available in our “Cookies Policy” below. To the extent required by applicable law, we will obtain your consent before using cookies or similar tools.Certain web browsers allow you to instruct your browser to send Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked. At this time, our Sites are not designed to respond to DNT signals or similar mechanisms from browsers. For information about Do Not Track, please visit: www.allaboutdnt.org.

HOW WE USE YOUR INFORMATION

We use the personal information we obtain about you to perform our contract with you or to take steps at your request prior to entering into a contract with you, including to:
  1. Provide our services, products and other offerings to you.
  2. Provide a seamless and integrated experience across Connected Accounts.
  3. Establish, manage and administer your membership and account with us, including verifying customer information and carrying out billing functions. We reserve the right to use any contact information held on file (including email, mailing address, and telephone or mobile phone) to contact you when administering your membership.
  4. Provide a safe environment for our employees and members, including determining any potential COVID-19 exposure.
  5. Process and fulfil your purchases in connection with our membership opportunities, products and services (e.g., training sessions, retail purchases and spa treatments), and keeping you informed about the status of your membership and purchases.
  6. Provide customer support services.
  7. Manage career opportunities, including for recruitment purposes, candidate screening, interviewing and evaluation, and employee onboarding.
  8. Establish and manage our relationships with our vendors, providers, suppliers and consultants.
We also use the information we obtain based on our legitimate interests and business purposes, including to:
  1. We also use the information we obtain based on our legitimate interests and business purposes, including to:
  2. Provide you with a more personalised and relevant membership with STEEL.
  3. Communicate with you about our products and services, and send you promotional and other marketing communications. See the “Your Communication Preference” section below to learn how you can opt out of these communications.
  4. Communicate with you about, and administer your participation in, surveys, events, programs, contests, promotions and other offers.
  5. Enable our affiliated companies and business partners (e.g., on-premises cafes and charitable organisations we partner with) to provide you with products and services, and send you information that you requested or that we think may interest you about their products or services.
  6. Respond to your requests and inquiries.
  7. Manage our business relationships.
  8. Operate, evaluate, develop, manage and improve our business, including by operating, administering, analysing and improving our Sites, products and services; conducting research and developing new products and services; managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing, reconciliation and collection activities and other internal functions.
  9. Perform analytics (including market research, trend analysis, financial analysis, and anonymization of personal information);
  10. Protect against, identify and prevent safety and security issues, fraud and other criminal activity, claims and other liabilities; and
  11. Conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, and our policies and terms, and for the establishment, exercise or defence of legal claims, whether in court proceedings or in administrative or out-of-court procedures.
Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g., to process your payment). In this case, we may not be able to provide you with the product or service you have requested but we will endeavour to notify you if this is the case.We also may use the information we collect about you in other ways for which we will provide specific notice at the time of collection and obtain your consent if required by applicable law.

THIRD-PARTY ANALYTICS SERVICES

We use third-party web analytics services on our Sites, such as Google Analytics and ContentSquare. The service providers that administer these services use automated technologies to collect data (such as IP addresses) to evaluate use of the Sites.To learn more about these analytics services, please see our “Cookies Policy” below. To learn how to opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.

INTERNET OR DIGITAL ADS SERVICE

When you visit our Sites, we may collect information about your online activities for use in providing you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. This section of our Privacy Policy provides details and explains how to exercise your choices.
You may see certain ads on other websites because we engage third-party ad buying networks (such as Google Ads and Facebook). Through such ad networks, we can target our messaging to users through demographic, interest-based and contextual means. These networks track your online activities over time and across multiple websites by collecting information through automated means, including through the use of third-party cookies, web server logs, pixels and web beacons. The networks use this information to show you ads that may be tailored to your individual interests. The information our ad networks may collect on our behalf includes data about your visits to websites that serve STEEL advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Sites and on third-party websites that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts.

HOW WE SHARE YOUR INFORMATION

We share your personal information with our vendors and other advisors such as law firms and auditors, who perform services or functions on our behalf, such as vendors who assist STEEL in maintaining the Sites, sending postal mail and email, managing and updating member lists and records, analysing data, and facilitating customer service. In accordance with applicable law, we have entered into appropriate written agreements with our vendors and we do not authorise our vendors to retain, use or disclose the information for any purpose other than the specific purpose of performing services on our behalf or complying with legal requirements. However, in certain instances vendors may use aggregated, de-identified information for their reasonable business purposes such as improving their products or services or for statistical reporting. In addition, we may share your personal information with other businesses with which we partner to provide you with products, services or offers we believe may be of interest to you, including in-centre businesses and charitable organisations we partner with.In accordance with applicable law, we may disclose information about you:
  1. If we are required to do so by law or legal process (such as a court order or subpoena).
  2. In response to requests by government agencies, such as law enforcement authorities.
  3. To establish or defend our legal rights or to enforce our membership agreement, terms and conditions and other contracts with you.
  4. When we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss.
  5. In connection with an investigation of suspected or actual illegal activity or violation of our membership rules and policies.
We may otherwise disclose information where we have obtained your consent to do so. We also reserve the right to assign or transfer any information we have about you in the event of any merger, acquisition, sale of assets, sale of our business, joint venture, reorganisation, divestiture, dissolution, liquidation or other corporate transaction, involving us or any of our parent companies or affiliates.
Social Media and Third Party Apps: We may share information with social networks when you interact with the Sites (e.g., clicking a Facebook “like” button) or connect your social media accounts to a Site. If you elect to connect Third Party Apps to the Sites, your information may also be shared with these third parties. Please see below for more information on this, as we do not control these third parties or their privacy practices.

YOUR COMMUNICATION PREFERENCES

Where required by applicable law, we will obtain your consent to send you marketing communications. If you do not wish to receive any marketing emails, you can opt out of future mailings by clicking on the unsubscribe link located on the bottom of the relevant email. If you are a member and have an account on the Sites, you can unsubscribe at any time by logging in and adjusting your communications preferences. If you are a member, please note that even if you opt out of receiving promotional emails, you will continue to receive administrative and operational communications regarding your membership, such as notices regarding billing, session reminders or club closures.

COOKIES POLICY

We collect certain information by automated means when you visit the Sites, through various means such as “cookies”, “web beacons” and IP addresses, as described below. A “cookie” is a small text file that a website saves on your computer or mobile device when you visit the site. We use cookies to tell us whether you have visited us before or if you are a new visitor. We also use cookies to help us identify site features in which you may have the greatest interest. Cookies may also enhance your online experience by saving your preferences while you are visiting a particular site. Web beacons” (also known as Internet tags, pixel tags and clear GIFs) allow third parties to obtain information such as IP address, the URL of the page on which the beacon appears, timestamps, browser type, and the information in cookies set by the third party. The Sites use the following types of cookies and web beacons:
Strictly Necessary: These cookies are necessary for the Sites to operate properly and facilitate your use of its features. Without these cookies, certain services cannot be provided. These cookies help us understand information, such as your session ID and other server authentication information. This category of cookies should not be disabled. If you use your browser settings to block them, we cannot guarantee your security or predict how the Sites will perform during your visit. Examples of our strictly necessary cookies include:
  1. EqAuth.v1: We set this cookie to allow us to authenticate users on our websites.
  2. productToken: We set this cookie to enable online purchasing through the websites by remembering the unique ID of each product you want to purchase.
Functional: These cookies allow the Sites to remember choices you make and provide enhanced and more personal features. They can also be used to make sure the content we show is relevant to you – for example, if you are logged in as a member, we use a cookie to make sure we don’t show you a promotion for non-members. They can also be used to remember changes made to parts of our website that you can customized. Examples of our functional cookies include:
  1. activateJSON: We set this cookie to allow us to help remember and populate your member ID, last name and location when activating your online account.
  2. LPSessionID: This cookie is set by the va.v.liveperson.net domain to help enable and provide our LivePerson online chat feature.
Performance and Analytics: These cookies collect information about how you interact with the Sites, such as what pages you visit and if any errors have occurred. Information is used to improve how the Sites function. These cookies don’t collect information that identifies you, but generate statistical data about your use of our Sites. Examples of our analytics cookies include:
  1. AMCV_###@AdobeOrg: We set this cookie to allow our Adobe Analytics software to identify a unique website visitor.
  2. s_cc: We set this cookie to allow our Adobe Analytics software to determine if a website visitor has enabled cookies.
  3. JSESSIONID: This cookie is set by the .nr-data.net domain to determine which pages you visited and whether you received any errors while browsing those pages, and we use cookies to help debug and fix our site.
Targeting and Advertising: These help customise the content and information you receive on the site and to help deliver ads that we believe are relevant to your interests. Advertising cookies may be placed on the Sites by a third party with our consent, which then enables us to determine whether or not to show you a STEEL ad when you are browsing other sites. Third-party cookies we have allowed to be placed on the Sites for advertising purposes are listed below. Please visit the relevant third party’s site for more information on these cookies and how you can opt out of them.
  1. Bing: The MR, MUID and MUIDB cookies are set on our website to help identify a Bing user as someone who visited our website so that we can determine whether or not to show that user a STEEL ad on Bing. Click here for more information on Bing’s cookies.
  2. Facebook: The fr and other Facebook cookies are set on our website to help identify a Facebook user as someone who visited our website so that we can determine whether or not to show that user a STEEL ad on Facebook. Click here for more information.
  3. LinkedIn: The BizoID, BizoUserMatchHistory and lang are set on our website to help identify a LinkedIn user as someone who visited our website so that we can determine whether or not to show that user a STEEL ad or job listing on LinkedIn. Click here for more information.
  4. Yahoo: The B cookie is set on our website to help identify a Yahoo user as someone who visited our website so that we can determine whether or not to show that user a STEEL ad on Yahoo. Click here for more information.

TEXT MESSAGES

In certain instances, the Sites may allow you to elect to communicate with STEEL by using text message, including in connection with scheduling a visit to one of our STEEL locations. By electing to receive text messages, you are expressly consenting to receiving text messages made using an automatic telephone dialling system from STEEL or its service providers, and you also understand and agree that data rates and charges may apply and that you are solely responsible for all associated costs assessed by your telecommunication carrier or provider. Providing this consent is not a condition of becoming a member of STEEL or receiving any goods or services from STEEL.You may opt out from receiving text messages at any time by either replying STOP or END to a text you have from STEEL or by texting STOP or END to +84 93-1302177 at any time. Please note that you may receive a confirmation text acknowledging you have unsubscribed. Please allow five (5) business days to process your request.
STEEL Sai Gon Joint Stock Company, also known as STEEL offers you the option to engage in SMS text conversations about your job application. By participating, you also understand that message frequency may vary depending on the status of your job application, and that message and data rates may apply. Please consult your carrier for further information on applicable rates and fees. Carriers are not liable for delayed or undelivered messages. Reply STOP to cancel and HELP for help.
By opting-in to receiving SMS text messages about your job application, you acknowledge and agree that your consent data, mobile number, and personal information will be collected and stored solely for the purpose of providing you with updates and information related to your job application. We are committed to protecting your privacy and shall not share or sell your consent data, mobile numbers, or personal information to third parties under any circumstances.

THIRD-PARTY SITES AND CONNECTED ACCOUNTS

For your convenience, the Sites may contain links to other online services or otherwise enable you to connect with third party sites, features, plug-Ins, tools, widgets, social media platforms or apps such as Facebook, Instagram, Twitter, YouTube, Tiktok and Linkedin (collectively “Third-Party Sites”). or they may enable you to connect or link to, or otherwise use your STEEL account in connection with, Connected Accounts. Third-Party Sites operate independently from us, and the privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy policies of those third-parties. You acknowledge and agree that your interactions with those Third-Party Sites and Connected Accounts, and your rights and obligations when accessing and using Third-Party Sites and Connected Accounts, are not governed by this Privacy Policy and will instead be governed by the terms and policies of those Third-Party Sites, and we encourage you to carefully read those terms and policies, as they may differ from ours.
TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE ARE NOT RESPONSIBLE FOR THE NATURE AND CONTENTS OF ANY FOR THE PRACTICES OF, OR THE COLLECTION, USE OR SHARING OF YOUR PERSONAL INFORMATION BY, ANY THIRD-PARTY SITES OR CONNECTED ACCOUNTS.

HOW WE PROTECT PERSONAL INFORMATION

STEEL maintains administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.

INTENDED FOR USE BY ADULTS

The Sites are intended for use by adults, and you may use the Sites only if you are at least eighteen (18) years of age or, consistent with our membership policies, have parental consent if you are sixteen (16) or seventeen (17) years old. The Sites are not intended for or directed to children under the age of thirteen (13), and we do not knowingly collect or store any personal information from children under the age of thirteen (13).

UPDATES TO OUR PRIVACY POLICY

We may periodically update this Privacy Policy, in our discretion, to reflect change in our privacy practices, the Sites and applicable law. We will post a notice on the Sites to notify you of significant changes to our Privacy Policy and indicate at the top of this Privacy Policy when it was most recently updated. You should check this page from time to time to ensure you are happy with our current Privacy Policy.

CONTACT US

If you have questions regarding our Privacy Policy, please contact us at hello@steelsaigon.com. For general questions regarding STEEL, our Clubs or the Sites please visit http://wwwsteelsaigon.com/contact. Your feedback is always welcomed and appreciated.
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