PRIVACY POLICY

Last Updated: 20/08/2025
HKD CREATE IPA SOFTWARE (“Provider”, “we”, “us”) respects the privacy of our customers and is committed to protecting personal data when customers visit the website, purchase, activate, and use Create IPA v2.0 software.
This Privacy Policy explains the types of information that may be collected, the purposes for which such information is processed, the scope of processing, data retention periods, parties that may have access to the information, and customers’ rights regarding their personal data.

1. Purposes of Collecting and Processing Personal Data
The Provider collects and processes customer information for purposes necessary to provide products, services, and customer support, including:
• Confirming and reconciling payment transactions for the purchase or renewal of the right to use Create IPA v2.0.
• Providing and managing software usage rights.
• Creating and providing an activation code (Activation Code/License Key) based on the technical information necessary to verify the customer’s usage rights.
• Associating an activation code with technical identification information of the customer’s computer to the extent necessary to operate the software licensing mechanism.
• Supporting software installation, activation, and use.
• Receiving and resolving support requests, feedback, complaints, and refund requests.
• Detecting, preventing, and handling fraud, unauthorized use of activation codes, or violations of the Software Terms of Use.
• Fulfilling applicable legal obligations.
The Provider does not collect or use personal information for purposes unrelated to transactions, product delivery, customer support, or legal obligations, unless the customer has provided consent or otherwise permitted or required by applicable law.

2. Scope and Types of Information Collected
Depending on the payment method and use of the software, the Provider may process the following information:
2.1. Transactions in Vietnam
This may include:
• Mobile phone number provided by the customer in the bank transfer description.
• Information relating to the bank transfer transaction.
• Information necessary to verify and reconcile the payment.
• Computer identification information or technical information (Hardware ID) to the extent necessary to verify the activation code and software usage rights.
2.2. International Transactions
This may include:
• Customer’s email address.
• Information relating to the PayPal payment transaction.
• Information necessary to verify and reconcile the payment.
• Computer identification information or technical information (Hardware ID) to the extent necessary to verify the activation code and software usage rights.
The Provider does not request customers to provide banking passwords, OTP codes, PayPal passwords, or other confidential payment-account credentials.

3. Methods of Collecting Information
Information may be collected from:
• Information provided directly by the customer when making a transaction.
• Bank transfer descriptions.
• Information relating to PayPal transactions.
• Information provided by customers when contacting customer support.
• Technical information processed by the software during activation and verification of usage rights, to the extent necessary for the operation of the software.
The Provider only collects and processes information to the extent necessary for the purposes described in this Privacy Policy.

4. Use and Protection of Information
Customer information is used for the purposes specified in this Privacy Policy.
The Provider applies appropriate technical and organizational measures to protect personal data against unauthorized access, use, disclosure, alteration, or processing.
Access to personal data is limited to the extent necessary to perform activities related to transactions, software provision, customer support, and legal obligations.
However, customers should understand that no electronic transmission or storage method can guarantee absolute security in every circumstance.

5. Parties That May Access or Process Information
Customer information may be accessed or processed, to the extent necessary, by:
5.1. HKD CREATE IPA SOFTWARE
As the operator and provider of Create IPA v2.0, HKD CREATE IPA SOFTWARE is responsible for transaction management, activation-code issuance, customer support, and management of related information.
5.2. Payment Service Providers
Transaction-related information may be processed by payment intermediaries or relevant financial institutions, including banks and PayPal, in accordance with their respective procedures and policies.
5.3. Competent Government Authorities
Information may be provided to competent government authorities when such disclosure is necessary or required under applicable law.
The Provider does not sell, rent, or provide customers’ personal data to third parties for commercial purposes contrary to the purposes disclosed in this Privacy Policy.

6. Disclosure or Transfer of Data to Third Parties
Where the use of payment services, email services, storage services, technical support services, or other technology services involves the processing of personal data by third parties, such processing may take place to the extent necessary to provide the relevant services.
Relevant third parties are expected to comply with applicable requirements and policies concerning the data they process.
For services such as PayPal or other technology platforms selected and used by the customer, the customer should review the privacy policy and terms of the respective service provider.

7. Data Retention Period
Personal data will be retained for as long as necessary to:
• Process transactions;
• Provide and manage software usage rights;
• Provide customer support;
• Process refund requests;
• Resolve complaints or disputes;
• Fulfill legal, accounting, tax, or other obligations required by applicable law.
When the data is no longer necessary for the purposes described above, the Provider will delete, destroy, or otherwise process the data in accordance with applicable law and appropriate technical capabilities.
A customer’s request for deletion of personal data may not apply where the Provider has a legal obligation or lawful basis to retain the data.

8. Customer Rights Regarding Personal Data
Subject to applicable law, customers may exercise rights regarding their personal data within the scope permitted by law, including the right to request:
• Information about the processing of their personal data.
• Access to or review of personal data held by the Provider.
• Correction or updating of inaccurate information.
• Deletion of personal data where the applicable legal requirements are satisfied.
• Restriction of or objection to the processing of personal data where permitted by law.
• Other rights provided under applicable personal data protection laws.

9. Methods for Requesting Access, Correction, or Deletion
Customers may request access to, update, correction, or deletion of their personal data by contacting:
HKD CREATE IPA SOFTWARE
Phone: 0866482674
Email: createipa@gmail.com
When submitting a request, the customer may be required to provide information necessary to verify their identity and transaction in order to prevent personal data from being disclosed or modified by an unauthorized person.
The Provider will receive and process requests within an appropriate period in accordance with applicable law and the nature of each request.

10. Payment Information Security
The Provider does not request customers to provide:
• Banking passwords;
• OTP codes;
• PayPal passwords;
• Card security codes;
• Or other confidential authentication credentials associated with payment accounts.
Customers are responsible for protecting their login credentials and confidential information relating to their bank, PayPal, or other payment accounts.

11. Technical Data and Hardware ID
Create IPA v2.0 may use computer identification information or technical information (Hardware ID) to the extent necessary to operate the activation-code verification mechanism and manage software usage rights.
Such information is used for technical purposes related to software licensing and is not used for advertising or the sale of personal data.

12. Complaints and Concerns Regarding Personal Data
If a customer believes that their personal data has been processed for an unauthorized purpose, beyond the disclosed scope, or in a manner inconsistent with applicable requirements, the customer may submit a request or complaint to:
Email: createipa@gmail.com
Phone: 0866482674
The Provider will receive, review, and coordinate the handling of the request within a reasonable period appropriate to the nature of the matter and applicable law.
For complaints requiring additional verification, the processing time may be longer than the normal processing period, and the Provider will notify the customer where necessary.

13. Customer Responsibilities
Customers are responsible for providing accurate, complete, and up-to-date information when making a transaction or contacting the Provider.
Customers should not provide banking passwords, PayPal credentials, or other confidential payment-account information to any unauthorized person.
Customers are also responsible for protecting information received from the Provider, including activation codes and information relating to software usage rights.

14. Changes to This Privacy Policy
The Provider may update this Privacy Policy when necessary to reflect changes to the product, service-delivery methods, technology, or applicable laws and regulations.
Updated versions will be published on the website.
Customers are encouraged to periodically review this Privacy Policy for the latest updates.

15. Information of the Data-Collecting and Data-Managing Entity
Entity Name: HKD CREATE IPA SOFTWARE
Tax Identification Number: 014082001897
Address: Ban Nhap, Mai Son Commune, Son La Province, Vietnam
Phone: 0866482674
Email: createipa@gmail.com
Website: createipa.com

16. Legal Basis
This Privacy Policy is established based on applicable Vietnamese laws and regulations concerning personal data protection, consumer protection, electronic transactions, and other relevant legal requirements.
If applicable laws or regulations change, this Privacy Policy will be updated accordingly.