PRIVACY POLICY
INVO Ring Smart Ring Device & App | Mandala Hotel Management & Services Joint Stock Company (MHG)
Mandala Hotel Management & Services Joint Stock Company (MHG) (“INVO”, “we”) respects the privacy of our customers and is committed to protecting personal data in accordance with the Law on Personal Data Protection No. 91/2025/QH15 and its implementing regulations. This Policy explains how we collect, use, share and protect customers’ personal data when they use the INVO Ring product and the INVO app (the “Service”).
01.PERSONAL DATA WE COLLECT
1.1 Account information
Full name, phone number, email, delivery address, password.
1.2 Personalisation profile
Gender, date of birth, height, weight.
1.3 Health data from ring sensors
Heart rate, SpO2, skin temperature, sleep metrics, activity level, heart rate variability (HRV)
1.4 Device data
Ring serial number, firmware version, technical error logs, Bluetooth address.
1.5 Location data (if enabled)
Approximate location to sync time zones and certain region-based features.
1.6 Transaction data
Order history, payment method (we do not store card numbers), warranty codes.
1.7 Customer support data
Content of your communications with customer care, complaints, and warranty requests.
Your health data is sensitive personal data and is protected by stronger safeguards than basic personal data.
02.HOW WE USE YOUR DATA
- To provide the core features of the Service: syncing, analysing and displaying your health, sleep and activity metrics.
- To personalise recommendations and wellness information based on the data you provide.
- To process orders, delivery, warranty, returns and customer care.
- To improve product and app quality using anonymised or aggregated data.
- To send promotions and offers — only if you agree to receive them (you can unsubscribe at any time).
- To fulfil our legal obligations (issuing invoices, keeping accounting records, resolving complaints).
We do not sell, rent or share your personal data with third parties for advertising purposes without your consent.
03.LEGAL BASIS AND YOUR CONSENT
We process your personal data only with your explicit consent, when necessary to fulfil an order/contract with you, or when required by law. For health data, we always obtain your separate consent, distinct from the general terms, before collecting and processing it. You can withdraw your consent at any time in the Account Settings section of the app.
04.SHARING DATA WITH THIRD PARTIES
We only share your personal data with:
4.1 Technical infrastructure providers
Data storage, app operation — under contracts binding them to confidentiality and limited purposes of use.
4.2 Shipping providers
Only the minimum information needed for delivery.
4.3 Payment intermediaries
To process your transactions.
4.4 Competent state authorities
When a lawful written request is made.
We do not transfer your personal data to any other party beyond the cases above without your consent.
05.DATA SECURITY
Your data is encrypted in transit and at rest.
We apply strict access controls; only authorised personnel may access customers’ encrypted personal data, and only when genuinely necessary for their work.
06.DATA RETENTION
We retain your data for as long as you continue to use your account.
07.YOUR RIGHTS OVER YOUR PERSONAL DATA
| Right | Details |
|---|---|
| Right to know | which of your data is being collected and processed. |
| Right to access and request a copy | of your personal data. |
| Right to request correction | of inaccurate data. |
| Right to request deletion | of your personal data. |
| Right to withdraw consent and object | to the processing of data for marketing purposes. |
| Right to complain | to us or a competent state authority if you believe your rights have been violated. |
To exercise these rights, please contact us using the details in Section 10. We commit to responding within 72 hours of receiving a valid request.
08. USERS UNDER 18
Our Service is not intended for persons under 18. If you are a parent or guardian and discover that your child has provided personal data to us without your consent, please contact us so that we can delete the data.
09. CHANGES TO THIS POLICY
We may update this Policy from time to time. When there are material changes affecting the purposes of data processing, we will notify you and, where necessary, obtain your consent again before applying those changes.
10. CONTACT
If you have any questions about this Privacy Policy or wish to exercise your rights over your personal data, please contact:
Thank you for trusting INVO Ring with your health.