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Legal framework & operating rules · Da Nang Data Exchange Governance

Operating rules & data privacy policy

The legal framework governing listing, price appraisal, personal information protection, access control and dispute resolution on the Da Nang Data Exchange. It sets up a transparent, secure data-economy environment compliant with Data Law No. 60/2024/QH15.

  • Effective: July 16, 2026
  • Aligned with Decree 13/2023 & the Data Law
  • Highest legal basis

    Data Law 60/2024

    National pilot Type 2 exchange

  • Personal data protection

    Decree 13/2023/ND-CP

    De-identification & anonymization

  • System security

    Level 4 / Decree 85

    TLS 1.3 & AES-256 encryption

  • Pilot mechanism

    Resolution 136/2024

    VIFC Sandbox – financial center

Official Da Nang Data Exchange document

No.: 26/QC-DADEP/2026

Operating rules and personal data protection

Last updated: July 16, 2026 · Applies across the whole Da Nang Data Exchange ecosystem

This policy describes Our standards, rules and procedures for collecting, storing, appraising, processing and sharing information when You trade, list or use services on the Da Nang Data Exchange; it also establishes Your lawful privacy rights under Data Law No. 60/2024/QH15 and Government Decree No. 13/2023/ND-CP.

Important notice: By registering an account, issuing an API key, joining an auction or carrying out a transaction on the Da Nang Data Exchange, You confirm that You have read, understood and agree to comply with all provisions of this document.

011. Interpretation and definitions

General interpretation

Words with an initial capital letter have the meanings defined under the following conditions. These definitions have the same meaning whether they appear in the singular or plural, active or passive, in contractual commitments on the Da Nang Data Exchange.

Definitions

Account
A unique, identified and authenticated account (through VNeID or an enterprise digital signature) created for You to access Our Service or the Da Nang Data Exchange modules.
Exchange Operator (Company / Operator)
Refers to the Data Innovation & Exploitation Center under the Da Nang People's Committee (24 Tran Phu, Hai Chau ward, Da Nang City) and the technical partners that help operate the Da Nang Data Exchange.
Personal Data
Any information relating to an identified or identifiable individual under Decree 13/2023/ND-CP and the Personal Data Protection Law. Commercially traded datasets on the Exchange must go through de-identification before listing.
Service
The entire Da Nang Data Exchange portal, including the Commercial Data Exchange, the Data Auction Hall, the Open Data Portal, the Sandbox test environment and integrated intermediary APIs.
Service Provider
Any licensed individual or organization that processes data on behalf of the Operator for custody, secure multi-party computation (MPC), escrow payment or data quality appraisal.
Usage Data
Data recorded automatically by the system (access logs, IP address, user agent, tokens / SQL commands executed in the Sandbox, session encryption parameters).
You / Participant
An individual, company, government agency, research institute or lawfully authorized representative accessing or using the Da Nang Data Exchange Service.

022. Collecting and using Your personal data

Types of data collected

a. Basic personal data

While verifying your Da Nang Data Exchange membership, We may ask You to provide:

  • Full name, date of birth, citizen ID number or Level 2 VNeID electronic identifier.
  • Organizational / business email address and official contact phone number.
  • Legal entity name, enterprise code / tax code, business registration certificate.
  • Public digital signature details (USB token or Smart CA) used to sign digital contracts.
b. Usage data and technical logs

Collected automatically to ensure Level 4 information security:

  • Internet Protocol (IP) address, browser type and version, device identifier.
  • Time and frequency of module access, API key call history, time spent on pages.
  • Logs of command interaction in the Sandbox (CPU/RAM consumption, functions invoked).
c. Tracking technologies and cookies

We classify and are transparent about the use of cookies on the Da Nang Data Exchange Portal as follows:

Necessary cookies

Login session and CSRF authentication. They cannot be turned off because they are needed to prevent transaction fraud.

Optional cookies

Remember language (VI/EN), font size and the user's preferred search filters.

Analytics cookies

EMC traffic statistics to Ministry of ICT standards; the data is fully anonymous.

033. Using Your personal data

We use personal data only in cases that strictly comply with a legal basis:

  1. 1.Maintaining and providing the Service: Creating accounts, issuing API keys, monitoring availability of listed datasets.
  2. 2.Performing data sale contracts: Generating automatic electronic contracts, reconciling escrow cash flow, handing over DRM distribution keys.
  3. 3.Notices and communication: Sending notices of bid price changes, Sandbox session expiry alerts, contract updates and cybersecurity announcements.
  4. 4.Managing support requests and complaints: Supporting data quality appraisal and hash-checksum reconciliation when a data product is disputed.

Sharing information with third parties

We never sell or commercialize users' personal information. Information is shared only with: banking payment partners (to carry out escrow), competent authorities (upon an official written request under the Cybersecurity Law), and the counterparty to a data sale contract that both sides have electronically signed and approved.

044. Retaining Your personal data

The Operator retains personal data only as long as necessary for the processing purpose or for legal obligations under the Accounting Law and the Law on Electronic Transactions.

Data categoryMaximum retention periodBasis & purpose
Member account informationFor as long as it is kept + 24 monthsHandling disputes that arise after an account is closed.
Electronic contracts & fee payment records10 years under the Accounting LawState financial audit and tax settlement obligations.
Audit logs & Sandbox access24 monthsLevel 4 information security monitoring and incident tracing.
Support records & complaint tickets24 months from ticket closureService quality assurance and protecting the arbitration board's rights.

Deletion and anonymization after expiry

When the retention period ends, the system automatically triggers one of the following: permanent deletion (secure wipe) from the active database; distributed, AES-256-encrypted cold backup; or fully irreversible anonymization into non-personal statistical data for macro digital-economy research.

055. Transferring Your personal data

All Da Nang Data Exchange data is stored and processed at the Da Nang Data Center (Tier III+) in Da Nang, Vietnam.

Where data must be transferred abroad (for example when integrating international cloud computing in the VIFC Sandbox), the Operator strictly follows the procedure of preparing a cross-border data transfer impact assessment (DPIA) under Article 25 of Decree 13/2023/ND-CP and obtains written approval from the Department of Cybersecurity and High-Tech Crime Prevention (A05) — Ministry of Public Security.

066. Right to delete and correct data

You have the full rights of a data subject under the Personal Data Protection Law, including:

  • The right to be informed and the right to consent to / withdraw consent for the processing of personal data.
  • The right to access, view, correct or request a copy of your personal data.
  • The right to request deletion or destruction of your personal data when you no longer wish to use the service.
  • The right to object to or restrict data processing for marketing or promotional purposes.

To exercise these rights, You can go to Account Settings > Privacy on the Da Nang Data Exchange or send a written request to the Data Protection Officer (DPO) at dpo@sandulieu.vn. Requests are handled within 72 working hours.

077. Disclosing personal data in special circumstances

The Operator discloses personal information only in cases required by law:

Law enforcement

When there is a written order or decision from a Court, the Procuracy or an investigating agency following proper procedural law.

Emergency prevention

To promptly stop cyberattacks that sabotage critical national infrastructure or large-scale financial fraud.

088. Security & information safety standards

The Da Nang Data Exchange is classified as a Level 4 information system under Decree 85/2016/ND-CP and applies defense-in-depth technical measures across the board:

End-to-end encryption

Data travels over HTTPS with TLS 1.3; data stored at the Data Center is encrypted with AES-256 GCM.

Multi-factor authentication (MFA)

Level 2 VNeID or PKI digital signature verification is mandatory for every bid or disbursement.

Container Sandbox isolation

Analysis environments run in network-isolated (air-gapped) containers, with raw-data export strictly prohibited.

Immutable log

Every access is hashed and anchored on a blockchain, ensuring legal evidentiary value.

099. Details on processing Your personal data

The infrastructure service providers We authorize operate under a strict Data Processing Agreement (DPA):

Customer support & incident management platform

The system that receives feedback and technical support runs on dedicated infrastructure, ensuring communications and attachments can be accessed only by authorized support staff (RBAC).

1010. Children's privacy

Our Service is designed for organizations, businesses and individuals aged 16 and over with full civil capacity. We do not knowingly collect personal data from anyone under 16.

If we find identifying information of a person under 16 in the system without the consent of a parent or lawful guardian, We will delete it from our servers within 24 hours.

1111. Links to other websites

Our Service may contain links to national public-service portals, commercial payment banks, or the Ministry of ICT's EMC monitoring system.

We are not responsible for the content or privacy policies of those third-party websites. You should review the privacy terms of each linked portal when you leave the Da Nang Data Exchange system.

1212. Changes & updates to these rules

The Operator may adjust and supplement these operating rules to comply with newly issued legal documents of the National Assembly, the Government and the Da Nang People's Committee.

Any change will be announced publicly on the Portal at least 15 days before it takes effect, and notified by email to all registered members.

1313. Contact information & feedback

If You have any questions or comments about these Operating Rules & Privacy Policy, please contact the Operator:

Operator

Data Innovation & Exploitation Center

Da Nang People's Committee

Address: 24 Tran Phu, Hai Chau ward, Da Nang City

Legal contact channels

Support hotline:
(+84.236) 3.817.366