Privacy Policy

1. Data Controller Identity

This Privacy Policy applies to the website operated by Napster MarTech (hereinafter “Napster”, “we”, “us”, or “our”).

Company address: TODO_CLIENT_COMPANY_ADDRESS

Data Protection Officer: TODO_CLIENT_DPO_EMAIL

2. Data We Collect

When you submit the “Request a Demo” contact form on our website, we collect the following personal data:

• Contact information: full name, work email address, company name, job title
• Business context: primary marketing challenge (selected from a dropdown)
• Marketing attribution parameters: UTM source, medium, campaign, content, and term — captured automatically from the URL when you arrive via an advertisement
• Technical identifiers: IP address and browser user-agent string, collected server-side at the time of form submission

We do not collect sensitive personal data categories (health data, biometric data, racial or ethnic origin, political opinions, or similar special categories under PDPA Decree 13/2023).

3. Third-Party Data Sharing

We share certain personal data with the following third-party platforms for the purposes described:

4. Legal Basis for Processing

We process your personal data under the following legal bases as defined by Vietnam PDPA Decree 13/2023:

• Consent — By submitting the contact form and checking the consent checkbox (PDPA consent), you explicitly consent to the collection and processing of your personal data for the purposes described in this Policy.
• Legitimate interest — We use aggregated analytics data (via Cloudflare Zaraz / GA4) to understand how visitors use our website and improve our services. This processing does not identify individual users.

You may withdraw your consent at any time by contacting us at TODO_CLIENT_DPO_EMAIL. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

5. Data Retention

• Lead notifications in Lark: retained for as long as required for the client relationship management purposes, subject to the client's own data retention policy and Lark's data processing terms.
• Analytics data (GA4 via Cloudflare Zaraz): aggregated and anonymised; individual session data retained per Google Analytics default retention settings (14 months).
• Ad platform conversion data: TikTok, Meta, and Google Ads retain conversion event data per their respective platform data retention policies.
• Server logs: IP addresses and user-agent strings processed transiently at the edge (Cloudflare Workers) and not stored server-side beyond the request lifecycle.

6. Your Data Subject Rights

Under Vietnam PDPA Decree 13/2023, you have the following rights regarding your personal data:

• Right of access: request confirmation of whether we hold your personal data and obtain a copy of it.
• Right to correction: request that we correct inaccurate or incomplete data we hold about you.
• Right to erasure: request deletion of your personal data, subject to our legitimate business and legal obligations.
• Right to object: object to our processing of your personal data where we rely on legitimate interest as the legal basis.
• Right to data portability: request a copy of the data you provided to us in a structured, commonly used format.

To exercise any of these rights, contact our Data Protection Officer at: TODO_CLIENT_DPO_EMAIL. We will respond within 30 days of receipt of your request.

7. Cookies & Tracking Technologies

Our website uses the following tracking technologies:

8. Contact for Data Requests

For all data privacy inquiries, requests to exercise your rights, or complaints regarding our processing of your personal data, please contact:

We are committed to resolving any complaints about our collection or use of your personal data. If you are not satisfied with our response, you have the right to file a complaint with the relevant data protection authority in Vietnam.