Operating Regulations

I. PROVISIONS ON OPERATING CONDITIONS

1. Information Published on the Pebbles E-commerce Platform

1.1. Information about the owner of the Pebbles E-commerce Platform

a) Company name

• Vietnamese name: CÔNG TY TNHH PEBBLES VIỆT NAM
• Foreign name: PEBBLES VIETNAM LIMITED LIABILITY COMPANY

b) Head office address

• Floors 17 & 18, The Nexus Building, No. 3A-3B Ton Duc Thang Street, Sai Gon Ward, Ho Chi Minh City, Vietnam
• Telephone: +31654913649
• Email: loan.dnh@pebbles.vn
• Business registration certificate no.: 0319189328
• Date of first issue: 29/09/2025 — Issued by: Business Registration Office, Ho Chi Minh City Department of Finance

c) Legal representative

• Full name: ĐINH NỮ HỒNG LOAN — Gender: Male
• Title: Director
• Date of birth: 07/05/1987 — Nationality: Vietnamese
• Citizen ID no.: 052187011516 — Date of issue: 16/02/2022 — Issued by: Police Department for Administrative Management of Social Order
• Permanent address: A1601 City Garden, 59 Ngo Tat To, Thanh My Tay Ward, Ho Chi Minh City, Vietnam
• Contact address: (as above)

d) Information about the Pebbles E-commerce Platform

The Pebbles e-commerce service platform is operated and developed by PEBBLES VIETNAM COMPANY LIMITED. It is an e-commerce environment connecting Service Providers — enterprises, organisations, business households, etc. — with Service Users in fields including, but not limited to, everyday-life services, family care services and related services provided by third-party Service Providers in accordance with the law.

In addition, Pebbles provides technological and informational support tools (including features based on artificial intelligence) to assist users in searching for, accessing and selecting suitable services. These tools are for reference only, do not constitute professional advice and do not replace services or advice from individuals or organisations qualified to practise under the law.

2. Privacy Policy

a) Purpose and scope of collection of user information

Purpose of collecting information

The Pebbles E-commerce Platform collects users' information in order to authenticate accounts; to adjust the content users post so that it fits the layout and content of the floor; to handle matters relating to service booking orders; to manage information serving technical support activities and the resolution of disputes and complaints (if any); and to respond to questions or carry out other customer requests.

Scope of information collected — Service Users

Information is collected to serve the need to connect users with services, ensuring strict compliance with personal data protection under Decree No. 13/2023/ND-CP.

Documents and information collected:

• Basic personal information: full name, date of birth, gender, place of residence (province/city).
• Contact information: personal telephone number, personal email address.
• Additional verification information (on request): in certain cases necessary to verify identity, handle complaints, ensure transaction safety or comply with the law, Pebbles may require Service Users to provide additional information or verification documents.

Data collection and consent process:

• Step 1 — Account creation: the Service User enters a personal email address or telephone number and sets a password.
• Step 2 — Providing account information: the Service User fills in their full name, address and date of birth.
• Step 3 — Consent to data processing: the system displays a clear notice regarding "Consent to the processing of personal data". The Service User must actively click "Agree" before the system enables the profile update feature. The notice sets out: the purpose of collection (to deliver the services); the scope of the information collected; and the parties with whom the data is shared.
• Step 4 — Storage and security: once collected, the data is encrypted and stored securely in the Pebbles Platform database. Service Users have full rights to edit, hide or request the complete deletion of their personal data on the system at any time.

Scope of information collected — Service Providers

Complete legal information is collected in order to verify legal capacity, prevent fraud and protect consumers' interests on the floor.

Documents and information collected:

• Identification information: enterprise/organisation name, tax code/enterprise code, head office address (per the Business Registration Certificate), and the name of the legal representative.
• Verification documents: a scan/photograph of the Enterprise Registration Certificate or equivalent legal document.
• Contact person information: contact person's full name, enterprise/contact person's telephone number, and work email (use of an email on the enterprise's domain is encouraged for verification purposes).

Collection and verification process:

• Step 1 — Account registration: the Service Provider accesses the platform, selects the "Service Provider" account type and completes the basic information in the online registration form.
• Step 2 — Providing supporting documents: the Service Provider provides the basic information required by the system, including the name of the enterprise/business household/service provider, contact details, business address and other information serving account creation.
• Step 3 — Service agreement: the Service Provider reads and confirms agreement with the platform's Terms of Service and Data Privacy Policy (by ticking the "I agree…" checkbox).
• Step 4 — Information review (verification): the floor's operations team cross-checks the declared information and attached documents against the data on the National Business Registration Portal and the Tax Authority portal to confirm the provider's operating status.
  • If the information matches and is valid: the account is verified so that services can be posted.
  • If there are doubts: the administrator requests clarification and additional records or information before deciding whether to verify or refuse to verify the account.

b) Scope of use of user information

The Pebbles Platform uses the personal information provided by Customers to:

• Assist Customers with any questions or concerns relating to the products/services they are interested in;
• Provide information relating to products/services and new offers/promotions if the Customer has subscribed to email notifications;
• Prevent activities that damage user accounts or activities involving impersonation of members;
• Contact and deal with Customers in special cases;
• Support the customer care system, customer management, customer care and the receipt of feedback;
• Where required by law: cooperate in providing members' personal information at the request of judicial authorities, including the Procuracy, the Court and investigating Police authorities, in connection with a Customer's conduct in breach of the law.

c) Data retention period

Pebbles retains the personal data of Service Providers and Service Users according to each purpose of use and the status of the account:

While the account remains active: account data, profile information, booking history and other data generated are retained while the account remains active and for as long as necessary for Pebbles to provide, maintain and manage the services.

When the user closes or deletes the account: Pebbles ceases to provide the services associated with the account and reviews the related data. Data that no longer serves a processing purpose and is not subject to continued retention will be deleted or destroyed in accordance with Pebbles' procedures. For data relating to service listings, transaction history, verification, complaints, disputes, violations, or data Pebbles is obliged to retain by law, Pebbles continues to retain it for as long as necessary under the applicable rules.

When the user withdraws consent or requests deletion of personal data: users have the right to withdraw consent to the processing of personal data where the processing is based on that consent, and the right to request deletion of personal data in accordance with the law. On receiving a request, Pebbles reviews the data by type and processing purpose; for data whose processing no longer has a legal basis or no longer serves a necessary purpose, Pebbles deletes, destroys or otherwise handles it in accordance with the request. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal and does not apply where Pebbles has another legal basis for continuing to retain or process the data.

Data subject to continued retention: certain data may need to be retained after the account is closed or the user requests deletion, including data serving the performance of legal obligations, the resolution of complaints and disputes, the prevention and handling of violations, the protection of the lawful rights and interests of Pebbles, Service Providers or Service Users, or compliance with requests from competent State authorities. Once the retention period expires or the grounds for continued retention cease to exist, Pebbles deletes or destroys the data in accordance with the rules.

Determining the start and length of retention: Pebbles determines the retention period based on the point at which the data was collected or generated on the platform, the status and lifespan of the account, the processing purpose, the point at which the transaction arose, and the retention period prescribed by law. The system records the date and time of creation, updates, changes in account status and data processing events as the basis for managing and controlling retention periods and for carrying out requests for deletion or restriction of processing.

d) Organisations and individuals who may access personal information

Pebbles may share Customers' personal information with the parties below. The information may include account identification details and user account history, name, address, telephone number, email address, or anything else Pebbles is permitted by law to provide:

• Third parties providing general content and services (such as registration, transaction and customer support services, or other software services to improve the platform's quality and services);
• Third parties providing contracted services supporting Pebbles' business operations (such as fraud investigation, invoice collection, affiliate and reward programmes and customer support);
• Other third parties to which the Customer has asked Pebbles to send the Customer's information (or to which the Customer has consented when using another specific service);
• Law enforcement agencies, other government bodies or third parties, in order to respond to requests for information relating to criminal investigations, alleged unlawful activity, or any other activity that could expose Pebbles, the Customer or any other user to legal liability;
• Other authorities involved in investigating fraud, intellectual property infringement, copyright infringement or other unlawful activities, as Pebbles determines to be necessary or appropriate, or under a confidentiality agreement, or as required by law;
• Other business units or investors with which Pebbles.vn plans to enter into investment cooperation, merge, or by which it is acquired. In all such cases, Pebbles will require those entities to apply this information privacy policy to the Customer's personal information.

e) Measures to protect users' information and data

The information systems serving Pebbles' operations are designed, deployed and operated on the principle of ensuring cyber security and network information security, meeting the information system protection requirements prescribed by the law on network information security.

System infrastructure security

• The system is deployed on Amazon Web Services (AWS) infrastructure hosted in data centres meeting requirements for physical safety, cyber security and business continuity.
• Servers are configured on the principle of functional separation between application servers, database servers and storage systems in order to limit the risk of unauthorised access.
• Access to administration servers is available only to authorised accounts, through secure connections, and is fully recorded in system logs.
• Unused service ports are disabled or have restricted access.

Transmission security

• The system uses the HTTPS (SSL/TLS) protocol to encrypt data exchanged between users and the server.
• Login credentials, personal data and transaction data are transmitted over an encrypted channel to prevent the risk of eavesdropping, alteration or data theft.

Account management and access control

• The system authenticates users through accounts and passwords.
• For system administration staff, permissions are granted on the principle of least privilege.
• Logins, data changes, permission changes and system administration activities are all recorded in logs to support inspection, monitoring and traceability.

Data protection

• The personal information of Service Users and Service Providers and the data generated are stored and managed on the corresponding storage components of the system.
• Protection of login credentials: user passwords are not stored in plain text and are processed using the system's credential protection mechanism before storage. Access to authentication data is restricted to authorised components and accounts.
• Protection of stored data: data is protected through encryption-at-rest mechanisms and the security policies of the corresponding infrastructure service. The PostgreSQL database on Viettel vDBS applies Encryption at Rest in accordance with the service configuration.
• The system applies access control mechanisms, restricts direct access to the database and controls permissions on a need-to-know basis.

Logging and information security monitoring — the system maintains logging for key activities:

• Account login and logout;
• Changes to account information;
• Posting, editing and deleting service information;
• Changes to administration permissions;
• Errors arising during operation;
• Abnormal access or activity showing signs of an attack.

System logs are stored securely and only designated personnel have the right to access them.

Cyber-attack prevention

• Control of external access;
• Limits on consecutive failed login attempts;
• Detection and prevention of abnormal access;
• Validation of input data to mitigate SQL Injection, Cross-site Scripting (XSS) and Cross-site Request Forgery (CSRF);
• Regular application of security patches for the operating system, software and system components.

Data backup and recovery

• System data is backed up periodically in accordance with internal procedures.
• Backups are stored independently of the main operating environment.
• The Company periodically tests the ability to restore data from backups.

Information security incident testing and handling — on detecting an incident, the process is:

1. Detect and record the incident;
2. Analyse the cause;
3. Isolate the affected area;
4. Remediate and restore system operations;
5. Verify data integrity;
6. Prepare a report and implement measures to prevent recurrence.

f) Methods and process for receiving requests to delete, destroy or restrict data processing

Users have the right of access to check, update, amend or delete their own personal data by logging into their account on the Pebbles Platform and editing their personal information, or they may ask Pebbles to assist.

Where a consumer discovers that their personal information has been used for the wrong purpose or outside the scope of use, or wishes to request the deletion, destruction or restriction of data processing, the user may submit a complaint to PEBBLES VIETNAM COMPANY LIMITED by:

• Submitting information via the Contact section on the platform: https://Pebbles.vn/lien-he
• Calling the hotline: +84 901 345 874
• Sending an email to: Info@Pebbles.vn
• Sending a written document by post or delivering it in person at the company's head office: Floors 17 & 18, The Nexus Building, No. 3A-3B Ton Duc Thang Street, Sai Gon Ward, Ho Chi Minh City, Vietnam.

The time limit for the Company to handle a report relating to a customer's personal information is 05 working days from the date the complaint is received.

In all cases, Pebbles gives priority to negotiation and conciliation with the Customer. Where negotiation and conciliation are unsuccessful, either party has the right to bring the matter before the competent People's Court for resolution in accordance with the law.

g) Online payment security policy

The policy on payment transactions using domestic and international cards ensures compliance with the security standards of the Payment Gateway Partners, including:

• The SSL (Secure Sockets Layer) internet data security standard issued by GlobalSign;
• The PCI DSS payment information data security standard certification provided by Trustwave;
• The MD5 128-bit encryption standard;
• The principles and rules on information security in the banking and finance sector as prescribed by the State Bank of Vietnam.

Commitments:

• Customers' payment card information is not stored on the website's system but is held and secured to the international PCI DSS standard at the Payment Gateway Partners.
• Customers access the website via the HTTPS protocol.
• Customers have the option of using OTP for access and transactions.
• The internal system between the Payment Gateway Partners' modules uses encrypted key exchange methods: internal data is encrypted using a private & public key pair, ensuring data confidentiality and integrity.

Pebbles.vn's payment transaction security policy applicable to Customers on the platform:

• Pebbles.vn does not directly store customers' card information. Card information security is handled by the Payment Gateway Partners.
• For international cards: payment card information capable of being used to initiate a transaction is not stored on Pebbles.vn's system. The Payment Gateway Partners store and secure this information.
• For domestic cards: Pebbles.vn stores only the order/booking code, the transaction code and the bank name.

Points to note when paying online:

• Use only websites holding a secure payment certificate.
• Never lend your card or account to another person to make payment on the website.
• Where unintended transactions arise on Pebbles.vn, customers should contact the customer care hotline published on the website and the hotline of the payment gateway/bank through which the transaction arose.
• Check your bank account regularly to ensure that all card transactions remain under your control.

h) Rules on AI and conversation data

Users' conversation content and interaction data on the platform may be collected, stored and processed by Pebbles in order to:

• (a) Serve the operation of the system, raise service quality and improve the user experience;
• (b) Analyse, evaluate and develop features, including technology-based support tools.

Pebbles undertakes that:

• (c) Conversation content and interaction data will not be used to make decisions substituting for the professional advice or services of individuals or organisations qualified to practise under the law;
• (d) Conversation content and interaction data will not be shared with any third party, except with the user's consent or at the request of a competent State authority in accordance with the law.

3. Rights and Obligations of the Parties

3.1. Rights and Obligations of the Management Board of the Pebbles E-commerce Platform

a) Rights of the Management Board of the Pebbles E-commerce Platform

• To provide services to participating Members after they have completed the procedures and mandatory conditions set out by the Platform.
• To store Members' registration information and regularly update related changes and supplements.
• To develop service policies applicable to each category of user on the platform. These policies shall be published on the Pebbles E-commerce Platform.
• Where there are grounds to establish that a Member has provided inaccurate, misleading or incomplete information, or has violated the law or Vietnamese fine customs and traditions, the Platform has the right to refuse, temporarily suspend or terminate that Member's right to use the services.
• To immediately terminate a Member's right to use the services upon discovering that the Member has been convicted or is serving a sentence, where the Member's continued activity could expose the Platform to legal liability, or where the Member engages in fraud, impersonation, market disruption, conduct causing disunity among other Members, or activities violating the applicable laws of Vietnam.
• To remove listings, or edit or delete the content of information about those listings, upon discovering that the service information is not genuine or is fake.
• Where membership and the right to use the services are terminated, all rights granted to the Member shall automatically cease to be valid and be terminated, and any service information already posted shall also be taken down.
• To retain the copyright in the services and the content on the Platform in accordance with the laws of Vietnam on intellectual property protection. All logos and content in the various languages belong to the Platform. Any unlawful copying, use or dissemination of the above ownership rights is strictly prohibited.
• To reserve the right to change the service price list and payment methods during the period of providing services to Members (in the case of Service Providers) according to the Platform's needs and capabilities, giving those Members one (01) month's prior notice.

b) Obligations of the Management Board of the Pebbles E-commerce Platform

• To register the e-commerce service platform with the competent State authority.
• To comply with regulations on the protection of customers' personal information.
• To ensure the safety and security of Service Providers' payment transactions, to handle complaints and to compensate for damage where payment information transmitted through the e-commerce website is altered, deleted, destroyed, copied, disclosed, moved without authorisation or misappropriated, causing damage to Service Users.
• To provide information on business operations at the request of competent State authorities in order to serve e-commerce statistical work, inspection, examination and the handling of e-commerce violations.
• To store information on transactions carried out through the website in accordance with accounting law; and to fully discharge tax obligations as required by law.
• To comply with the Commercial Law and related legal provisions on promotional activities.
• To comply with regulations on the protection of users' personal information.
• To establish and publish on the website a mechanism for receiving and resolving customer complaints about service information.
• To develop and publicly announce the Operating Regulations, Rules and Guidelines on transaction processes for Members; and to monitor and ensure the implementation of those regulations on the Website.
• To fully publish information about the website owner on the website homepage in accordance with the law:
  • Entity name: PEBBLES VIETNAM COMPANY LIMITED
  • Tax code: 0319189328
  • Head office: Floors 17 & 18, The Nexus Building, No. 3A-3B Ton Duc Thang Street, Sai Gon Ward, Ho Chi Minh City, Vietnam
  • Telephone: +31654913649
  • Email: Info@Pebbles.vn
• To support Members in using the tools and features serving the conduct of transactions and the use of utility services on the Platform.
• To receive Members' feedback in the course of operations.
• To be responsible for building the platform: research, design, procurement of hardware and software, Internet connectivity, and the development of policies serving the Platform's operation, within permitted conditions and scope.
• To have inspection and supervision mechanisms to ensure that the information provided by Members on the system is accurate and complete.
• To publicly announce the mechanism for resolving disputes arising in the course of transactions. Where a Service User comes into conflict with a Service Provider or suffers harm to their lawful interests, the Platform must provide the Service User with information about the Service Provider and actively assist in protecting their lawful rights and interests.
• To use best efforts, within the scope and conditions available, to maintain the normal operation of the Platform and to remedy incidents: technical machinery faults, software errors, Internet transmission systems, personnel, social upheaval, natural disasters, power outages, and decisions of State authorities or a related third-party organisation. However, where such incidents occur beyond the Platform's control and constitute force majeure events causing damage to Members, the Platform shall not bear joint liability.
• To promptly handle matters upon discovering, or receiving reports of, business conduct on the platform that violates the law:
  • a) Prevent and remove from the website service listings that are not genuine or that are fake, in accordance with the law;
  • b) Remove service information that violates the law within a maximum of 24 hours from receipt of a request from the competent State management authority;
  • c) Cooperate with intellectual property right holders to review and remove products infringing intellectual property rights in accordance with the process and procedures published in the Operating Regulations;
  • d) Warn, or refuse to provide services on a temporary or permanent basis to, individuals, enterprises and organisations engaging in conduct that violates the law;
  • đ) Other measures under the Operating Regulations of the Pebbles E-commerce Platform.
• To assist State management authorities in investigating business conduct that violates the law, and in resolving disputes and complaints: providing information about entities showing signs of, or engaging in, conduct violating the law to the competent State management authority; regularly updating keywords as recommended by State management authorities and filtering information by keyword before information on goods and services is displayed on the website; and receiving and responding to information in order to resolve complaints, reports and disputes on the E-commerce Activity Management Portal of the Ministry of Industry and Trade (online.gov.vn).
• To require Service Providers to provide complete information, documents and relevant certificates proving they satisfy the conditions to operate when registering to use the services, in accordance with the laws of Vietnam.
• To store the registration information of enterprises, organisations and individuals participating in the Platform and to regularly update related changes and supplements.
• To establish a mechanism allowing enterprises, organisations and individuals participating in the Platform to carry out the service process on the platform.
• To apply the necessary measures to ensure the security of information relating to the business secrets of enterprises, organisations and individuals and the personal information of consumers.

3.2. Rights and Obligations of Service Providers on the Pebbles E-commerce Platform

a) Rights of Service Providers

• To register, maintain, temporarily suspend or terminate a Service Provider account on the platform in accordance with the law and the Pebbles operating regulations.
• To have the features for posting services, managing orders and reporting revenue activated.
• To use the functions, tools and support services provided by Pebbles; and to access and manage the information and candidate profiles permitted to be provided, in accordance with the mechanism and scope prescribed by the platform.
• To request technical support from Pebbles and the receipt and resolution of reports, requests and complaints relating to the account, service listings and the use of services on the platform, in accordance with Pebbles' procedures.
• To have account information and data protected in accordance with the Privacy Policy and related legal provisions.
• To request the correction, updating or deletion of information within the scope permitted by law and in accordance with Pebbles' rules.

b) Obligations of Service Providers

• To provide complete, accurate and up-to-date information about the Service Provider, its legal representative, contact details and other information as required by Pebbles; and to be responsible for the accuracy, truthfulness and legality of the information provided.
• To bear full responsibility for the content of the information posted, and for the quality, legality and provision of services to Users. Where the services fall within a conditional business line, the Service Provider must ensure full satisfaction of the conditions prescribed by law; and must fully discharge obligations relating to tax, consumer protection, personal data protection and other related legal obligations.
• Not to post content or use the platform to carry out unlawful activities, misappropriate property, collect money contrary to regulations, or engage in conduct infringing the lawful rights and interests of Service Users.
• Not to request, collect, use, store or share the personal data of Service Users beyond the necessary scope or contrary to the law on personal data protection.
• To keep confidential the information, records and data of Service Users accessed through Pebbles; to use them only for the purpose of performing lawful services; and not to provide, transfer or use them for other purposes without a lawful basis.
• To provide complete information on the Business Licence and related documents proving eligibility to trade in the types of goods/services on the list of conditional business lines, in accordance with the rules of Pebbles.vn and applicable law.
• To fully discharge financial, tax and other obligations arising from the provision of services or transactions with Service Users.
• To proactively keep the account, login credentials and authentication methods secure; and to be responsible for activities carried out through the account, except where the fault is proven to lie with Pebbles.
• To cooperate with Pebbles in verifying information and handling reports, complaints, disputes, violations and requests from competent State authorities.
• To be responsible for the content of service information, the information provided to Service Users and the service-provision conduct carried out through its account; and to compensate and bear responsibility in accordance with the law if it causes damage to Pebbles or Service Users.

3.3. Rights and Obligations of Service Users on the Pebbles E-commerce Platform

a) Rights of Service Users

• To register, maintain, temporarily suspend or terminate an account on the Pebbles platform in accordance with the law and the Pebbles operating regulations.
• To access the service information provided by Service Providers on the platform; and to select services suited to their needs, circumstances and means.
• To be provided with information on the service position, service requirements, place of work, working conditions and other information relating to the services, within the scope of the information published by the Service Provider.
• To have personal information, records and data provided to Pebbles protected in accordance with the Privacy Policy and the law on personal data protection.
• To use the functions and tools supporting job search, application and profile management provided by Pebbles.
• To submit reports, requests and complaints relating to service listings, Service Providers or the use of services on the platform, and to have them received and handled by Pebbles in accordance with its rules.

b) Obligations of Service Users

• To provide personal information, records, qualifications, experience and other information completely, accurately and truthfully; and to be responsible for the information provided on the platform.
• To proactively update profile information when it changes and to ensure that the information provided to Service Providers through Pebbles is accurate and appropriate.
• To comply with the law, the operating regulations, the conditions of use and Pebbles' policies when using the platform.
• Not to use the platform to provide false or fraudulent information, misappropriate property, disseminate unlawful content, or engage in conduct infringing the lawful rights and interests of Service Providers, Pebbles or other users.
• Not to use another person's account, not to provide or transfer the account for another person's use, and to be responsible for keeping their login credentials confidential.
• Not to collect, copy, use or share without authorisation the information or personal data of Service Providers, other users, or information accessed through the platform.
• To pay fees in full and on time to the Management Board of the Pebbles.vn E-commerce Trading Floor (if any).
• To comply with the sanctions (penalties) imposed by the Management Board in respect of their violations.
• Not to act in any way that damages the reputation of the Pebbles.vn E-commerce Trading Floor, such as causing disunity among Members by using a second registered name, acting through a Third Party, or propagating and disseminating information detrimental to the Floor's reputation.
• To provide information on their business operations at the request of competent State authorities in order to serve e-commerce statistical work.
• To comply with the law on payment, advertising, promotions, protection of intellectual property rights, protection of consumers' interests and other related legal provisions when posting goods/services for sale online on the Pebbles.vn floor.
• To cooperate with Pebbles in verifying information and handling reports, requests, complaints, disputes and violations arising in the course of using the platform.
• To be responsible before the law for the content of the information and records, and for the acts carried out, through their account.

4. Methods for Receiving and Resolving Reports, Requests and Complaints

Pebbles establishes a mechanism for receiving and resolving reports, requests and complaints from Service Providers, Service Users and other interested parties on the principles of openness, transparency, timeliness and compliance with the law.

a) Methods of receipt

• Submitting information via the Contact section on the platform: https://Pebbles.vn/lien-he
• Calling the hotline: +84 901 345 874
• Sending an email to: Info@Pebbles.vn
• Sending a written document by post or delivering it in person at the head office of Pebbles Vietnam Company Limited: Floors 17 & 18, The Nexus Building, No. 3A-3B Ton Duc Thang Street, Sai Gon Ward, Ho Chi Minh City, Vietnam.

For reports, requests or complaints relating to accounts, service listings, job-seeker profiles or personal data, the sender must provide the information necessary for Pebbles to identify the account, the substance of the matter and the relief sought. Where necessary, Pebbles may request additional information and documents for verification.

b) Order and procedure for receipt and handling

The receipt and resolution of reports, requests and complaints is carried out in the following steps:

• Step 1 – Receipt: Pebbles records the report, request or complaint through one of the methods set out above and confirms receipt.
• Step 2 – Examination and verification: Pebbles examines the sender's information, the account concerned, the substance of the matter and the documents and evidence provided. For requests relating to personal data, Pebbles verifies the requester before taking any action in respect of the data.
• Step 3 – Classification and handling: The matter is classified according to its nature, including reports about accounts, service listings, job-seeker profiles, violations, personal data, platform operations or other issues. Pebbles applies handling measures appropriate to each case.
• Step 4 – Notification of outcome: Pebbles notifies the sender of the outcome, the measures taken or the next steps for resolution. Where more time is needed for verification, Pebbles notifies the sender of the processing status and the expected completion time.
• Step 5 – Closure and record retention: Once the matter has been resolved, Pebbles records the outcome and retains the related information and documents in accordance with the Company's data retention policy and the law.

c) Response and resolution timeframes

• Initial response: Pebbles acknowledges receipt of the report, request or complaint within a maximum of 02 working days from receipt of valid information.
• Ordinary issues: Pebbles expects to complete processing within a maximum of 05 working days from the date of receipt of all necessary information.
• Personal data requests: Pebbles gives priority to handling requests relating to data subjects' rights and does so within the timeframe prescribed by applicable law. Where it is necessary to verify identity, the scope of the data or the grounds for continued retention of the data, the processing time runs from the point at which Pebbles receives all necessary information.
• Complex matters: For matters involving multiple accounts or multiple parties, requiring verification of information from Service Providers or Service Users, showing signs of a violation of law, or requiring coordination with a third party or competent authority, the processing time may exceed the timeframes set out above. Pebbles will notify the sender of the reasons and the expected processing time.

d) Measures and tools supporting resolution

Depending on the nature of the matter, Pebbles may apply one or more of the following measures:

• Checking account information, service information and related data on the system;
• Checking system logs and the activity history relating to the matter;
• Requiring the Service Provider, Service User or other relevant party to provide or supplement information, documents and evidence;
• Temporarily hiding, locking or restricting access to accounts, service information or content showing signs of a violation during verification;
• Amending, removing or restricting the display of infringing content in accordance with Pebbles' rules;
• Taking measures relating to personal data at the valid request of the data subject and in accordance with the law;
• Coordinating with Service Providers, Service Users, service partners and competent State authorities where the matter falls within the scope requiring coordinated handling.

In all cases, Pebbles gives priority to resolution through discussion, negotiation and conciliation on the basis of respect for the parties' lawful rights and interests. Where the parties fail to reach agreement or the matter falls outside the scope of Pebbles' resolution, the parties have the right to request resolution by the competent State authority or the competent Court in accordance with the law.

5. Pricing Policy

5.1. Service prices on the platform

Fees are set out in the related policies published on the Platform from time to time. Account registration, the posting of service information and connection for service delivery are carried out in accordance with Pebbles' service policy in force from time to time.

5.2. Service fee policy for Service Providers

Where Pebbles introduces chargeable services (including but not limited to platform usage fees and commission fees), Pebbles publishes on the platform at least the following information:

• The name and content of the service;
• The applicable fee level;
• The method of calculating the fee;
• The date and period of application;
• Taxes and other charges (if any);
• The payment method and related conditions.

Where there is a change to the fee level or the fee policy, Pebbles publishes the change on the platform at least 15 days before the effective date, unless the law provides otherwise. Users have the right to consider, choose or decline to continue using the service.

6. Conditions or Restrictions on the Provision of Services

Pebbles is a platform providing connection services between Service Providers and Service Users. The provision and use of services are subject to conditions and limits designed to ensure the quality of information and the safety of the system, to protect users' lawful rights and interests, and to comply with the law.

6.1. Conditions for Service Providers

• They must register an account and provide complete and accurate information as required by Pebbles. Depending on the nature of the account and the services, Pebbles may require information and documents to verify identity, legal status and information serving the provision of services.
• They may only post service information that corresponds to what they can actually provide, is clear and truthful in content, and does not fall within business lines or activities prohibited by law.
• Pebbles has the right to refuse to publish, require the amendment of, temporarily hide or remove service information, or to temporarily lock or restrict an account, where the information is incomplete or inaccurate, shows signs of falsification, or breaches the Operating Regulations, the Privacy Policy or the law.

6.2. Conditions for Service Users

• They must provide the necessary, accurate and truthful information when registering an account, creating a profile or using the functions on Pebbles.
• They may use their account only to search for services, book services and use the services provided by Pebbles; they may not use the platform to engage in impersonation or fraud, disseminate unlawful content, or infringe the lawful rights and interests of others.

6.3. Limits on service hours

Pebbles' online services are provided 24 hours a day, 7 days a week, except during maintenance, system upgrades, the handling of technical incidents or force majeure events. Where this can be anticipated, Pebbles will notify users of the timing and scope of the impact.

6.4. Geographical limits

Pebbles provides connection services in the online environment and does not restrict access by administrative boundary, except where the law, a requirement of a competent State authority, or the particular nature of the service location provides otherwise. The scope of service delivery and the specific location are published by the Service Provider in each service listing.

6.5. Limits on eligible users

Users must satisfy the conditions for registering and using Pebbles under the law and Pebbles' Operating Regulations. Pebbles may apply verification measures to, restrict or refuse to provide services to accounts that do not meet the registration conditions, provide inaccurate information, show signs of falsification, or engage in conduct breaching the Operating Regulations, the Privacy Policy or the law.

6.6. Limits on volume and frequency of use

To ensure performance, safety and the stable provision of services, Pebbles may apply reasonable limits on the number of service listings, the number of requests, the frequency of operations, the size of uploaded files or other resources for each account or each type of service. Limits may be applied to prevent excessive use of the system, abnormal automated requests, content dissemination, spam, or conduct affecting the system and other users.

6.7. Conditions on service availability and safety

Pebbles may suspend or restrict the provision of services in the following cases:

• Maintenance, upgrade or modification of the system;
• Detection of a risk or incident affecting information security, data or the system;
• Detection of an account, service listing or activity showing signs of a breach of the law or of the Operating Regulations;
• Incidents affecting technical infrastructure, telecommunications networks, hosting services or infrastructure providers' services;
• Force majeure events or other circumstances beyond Pebbles' reasonable control.

Pebbles applies appropriate technical and operational measures to maintain the platform's availability, including access control, system monitoring, activity logging, periodic data backup and the implementation of recovery measures when incidents occur.

6.8. Moderation and restriction of service content

Pebbles applies a content moderation mechanism for service listings using technical measures combined with operational review and handling. The system is capable of automatically screening service listing content and detecting categories of content showing signs of unsuitability, including:

• Content that is advertising in nature, makes excessive claims or is misleading as to the service, the results of delivery and the scope of the service;
• Content requiring Service Users to pay money, pay fees, purchase materials, place deposits or make unusual payments in order to book a service;
• Content showing signs of advertising services that are not genuine, promising unusual results, or showing signs of fraud;
• Content showing signs of services connected with unlawful activities or activities posing a risk to the safety of Service Users;
• Content showing signs of directing Service Users to communication channels outside the platform such as Zalo, Telegram or similar channels in order to evade Pebbles' control, verification and user protection mechanisms.

The lists of keywords, content patterns and detection rules are developed, updated and adjusted by Pebbles according to actual circumstances; the detailed lists are managed within internal moderation procedures and are not published in full, in order to limit the ability of bad actors deliberately to alter content to circumvent the moderation mechanism.

Depending on the level of risk and the outcome of the review, Pebbles may apply one or more of the following measures:

• Refusing to publish, or requiring the Service Provider to amend, the service information;
• Temporarily hiding the service information pending review;
• Attaching a warning to, or restricting the display of, the service information;
• Removing infringing service information;
• Requiring the Service Provider to provide additional information and documents for verification;
• Temporarily locking or partially restricting the functions of the Service Provider's account;
• Suspending or terminating the account in cases of serious or repeated breach;
• Referring the matter to the responsible department for manual review, verification and handling where the system detects signs of risk but there is insufficient basis for an automated conclusion.

Automated moderation is a supporting measure for detecting and preventing risk; it does not entirely replace operational review, verification and handling in cases requiring specific assessment.

6.9. Cases of restriction or refusal to provide services

Pebbles has the right to refuse, restrict or suspend the provision of some or all services to a user in the following cases:

• Failure to meet the conditions for registering and using the platform;
• Providing false or inaccurate information, or information showing signs of fraud;
• Breach of the Operating Regulations, the Privacy Policy or Pebbles' other policies;
• Posting, sharing or engaging in conduct involving content that breaches the law;
• Conduct affecting the safety, security, stability or performance of the system;
• Use of automated tools, bots or technical methods to interfere with, exploit or circumvent Pebbles' control mechanisms;
• Repeat breach after Pebbles has issued a warning, required remediation or applied restrictive measures.

Depending on the nature and severity of the breach, Pebbles may issue warnings, require remediation, temporarily hide content, restrict functions, temporarily lock or terminate the account, and take other necessary measures in accordance with the law.

7. Payment Policy

7.1. Payment methods

Pebbles supports various payment methods supplied by licensed intermediary payment providers.

Payment transactions are carried out through the connection between Pebbles' system and the payment service provider's system; Users authenticate the transaction directly on that provider's system.

Pebbles does not provide intermediary payment services and does not store, manage or control Users' payment account information.

Users must use a valid payment account to carry out transactions.

Transactions are authenticated using the security mechanisms applied by the payment service provider, including but not limited to passwords, biometric authentication, OTP codes or other valid authentication methods.

Pebbles does not collect or store Users' sensitive authentication information, including but not limited to passwords, OTP codes or bank account details.

7.2. Payment policy when chargeable services are introduced

When introducing chargeable services, Pebbles publishes the following information before providing the service:

• The name and content of the service;
• The applicable fee level;
• The payment method and process;
• The service delivery period;
• Taxes and other charges, if any;
• The conditions for a refund and the cases in which no refund is available.

7.3. Refund policy

Fees and cancellation and refund conditions are set out in the related policies published on the Platform from time to time. The refund obligation rests with the Service Provider in accordance with its published policy; Pebbles supports the receipt and coordination of refund processing through the system and the intermediary payment service provider.

Refunds to Users are made through the intermediary payment service provider in accordance with that provider's procedures, with an expected processing time of 07 to 15 working days (except where a dispute or other issue arises).

Where a dispute arises, refund processing is carried out on the basis of: (i) the Service Provider's policy; (ii) the outcome of the dispute handling. Pebbles supports coordination and provides the relevant data.

Refund mechanism:

• Step 1: The Service User submits a refund request to pebbles.vn by email at info@pebbles.vn or hotline +84 901 345 874. Pebbles.vn receives the request and records the specific reason for processing.
• Step 2: Pebbles.vn verifies the service — contacting the service provider to check and confirm that the customer has not yet used the booked service.
• Step 3: Processing time is within 1–2 working days.
• Step 4: Pebbles.vn issues the refund — once confirmed, the refund is carried out directly on the Pebbles.vn business management system on MoMo (business.momo.vn — the online payment contract will be signed once confirmed).

7.4. Reward points, point refunds and redemption offers

Pebbles does not currently operate any points accrual, point refund or redeemable points mechanism.

Should such a mechanism be introduced in the future, Pebbles will publish how points are earned and used, the scope of application, the conditions, rates and limits for redemption, the validity period and the responsibilities of the parties. Redeemable points may not be converted into cash, unless the law provides otherwise.

7.5. Payment-related support

Where an issue relating to payment arises once Pebbles has introduced chargeable services, users may make contact via the Contact section (https://Pebbles.vn/lien-he), the hotline +84 901 345 874, email Info@Pebbles.vn, or by sending a written document by post or delivering it in person at the Company's head office.

8. Display Priority Policy

8.1. Display principles

Pebbles may apply criteria and technical mechanisms to sort, categorise and prioritise the display of service listings in order to help Service Users easily find and access suitable services. Currently, when posting a service listing, Service Providers may select the listing's display level in accordance with the platform's rules, including display priority by keyword, location, etc.

8.2. Main criteria affecting display

• Relevance to the search query: between the keywords, business line, skills, location and other information in the service listing and the search query;
• Completeness and suitability of the service information: the content, title, service description, place of work and related information;
• Posting date and remaining validity: listings that remain valid and are suitably updated may be prioritised over listings that have expired or are no longer available;
• Service delivery location: geographic position and the degree of fit with the search scope;
• Moderation status: listings must meet content, safety and operating regulation requirements before being displayed;
• Other technical criteria serving the improvement of searchability, result quality and platform performance.

Pebbles may adjust the criteria and the manner of sorting and display in line with its operations.

8.3. How display criteria are selected

Service Providers may manage their service listings using the functions provided by Pebbles. These choices are made at the Service Provider's own initiative and do not alter the content or conditions of the service, or the listing's relevance to Service Users. Service Users may use the search, filter and selection functions provided by Pebbles.

8.4. Principles applying to prioritised listings

Display priority does not mean that Pebbles confirms, guarantees or certifies the accuracy, quality, conditions or capability of the Service Provider. Prioritised service listings must still comply with Pebbles' content, moderation and operating condition requirements; where signs of a breach appear, Pebbles retains the right to temporarily hide, remove or restrict the display of the listing or to apply other handling measures.

9. Delivery Policy

Pebbles is an online connection service platform; it does not carry out the sale of goods and does not provide goods delivery services on the platform. Accordingly:

Information, records, service listings and electronic documents exchanged through the platform are handled electronically, using the functions provided by Pebbles and in accordance with the Operating Regulations.

10. Goods Return and Refund Policy

Pebbles does not carry out the sale of goods and does not supply goods on the platform; accordingly, no goods return or goods refund activity arises:

As regards service fees, should Pebbles introduce chargeable services in the future, any refund of fees will be made in accordance with the Payment Policy and the specific conditions of each service published before it takes effect.

11. Policy on the Method of Service Provision

11.1. Method of service provision

Pebbles provides connection services directly on the online platform, through the website and the functions integrated into the system. Users may access the platform using devices with an Internet connection and a compatible web browser in order to register an account, create a profile, post service information, search for services, book services and use other functions.

11.2. Service usage period and devices used

• Accounts are maintained so that Service Users and Service Providers can use Pebbles' functions in accordance with the platform's policies and for as long as the account remains active.
• At present, Pebbles does not limit the usage period of an active account and does not limit the number of devices that may access an account.
• Users are responsible for keeping their login credentials confidential and for not sharing their account with others.
• Pebbles may apply verification measures, limit the number of login sessions or temporarily restrict access where it detects signs of abnormal login, unauthorised account use or a risk to system safety.

11.3. Manner of use and main features

For Service Providers:

• Registering and managing an account;
• Providing and verifying Service Provider information;
• Creating, posting and managing service listings;
• Receiving and managing Service User information;
• Updating service status, including: booking, payment, booking confirmation;
• Interacting with Service Users;
• Managing profiles, service listings and activity on the platform.

For Service Users:

• Registering and managing an account;
• Creating and updating user information;
• Searching, filtering and viewing service information;
• Viewing Service Provider information and service listings;
• Following and unfollowing Service Providers;
• Saving and unsaving service listings;
• Booking suitable services;
• Managing history and information relating to the process of finding and receiving services on the platform.

11.4. Restrictions during use

Pebbles may apply limits or control measures in respect of:

• The number and frequency of service listings posted;
• The frequency of operations performed on the platform;
• The size and type of files permitted to be uploaded;
• The number of access or connection requests within a given period;
• Conduct showing signs of spam, use of automated tools or impact on the system.

Pebbles may temporarily restrict, lock or terminate the right to use an account where it detects conduct breaching the Operating Regulations, the Privacy Policy or the law, or affecting the safety, security and normal operation of the platform.

11.5. Service interruption periods

The services are provided online 24 hours a day, 7 days a week, except during maintenance, upgrades, the handling of technical incidents or force majeure events. Where this can be anticipated, Pebbles will give notice of the maintenance or service interruption through appropriate means on the platform.

11.6. Services booked in advance for later use

• Pebbles may offer certain service packages or service products paid for in advance and used in the future, in accordance with the information published on the platform from time to time.
• For such packages, Users are entitled to use the services within the scope, period, number of uses and applicable conditions published at the time of purchase. Unless otherwise provided, the benefits in a service package may only be used within the package's validity period and may not be converted into cash.
• Booking the use of services within a package remains subject to the Provider's operating schedule and capacity, and to the booking, rescheduling, cancellation and refund policies published on the platform.
• The specific conditions on the usage period, scope of application, benefits, usage restrictions, exchange, cancellation or refund (if any) will be published on the information page for each service package or corresponding programme.

12. Service Termination and Refund Policy

12.1. Cases of service termination

• The Service Provider or Service User requests termination of the account of their own initiative or no longer wishes to use the services;
• The user deletes the account using the function provided by Pebbles on the platform;
• Pebbles terminates or suspends the provision of services at the request of a competent State authority, as required by law, or due to a change in the platform's operations;
• Pebbles terminates the account because the user has breached the Operating Regulations, the Privacy Policy or the law;
• Other cases as agreed between Pebbles and the user or as provided by law.

On termination of the account, the user will no longer be able to use the functions available to the terminated account. Obligations that arose before termination continue to be performed. Termination of the account does not affect obligations to store, provide or preserve information and data where the law requires Pebbles to continue retaining them.

12.2. Time of service termination

• Where the user requests termination of the account of their own initiative: the services terminate from the point at which Pebbles confirms the termination request or the system completes the deletion of the account.
• Where Pebbles terminates the account for breach: the time of termination is determined by Pebbles' notice or the point at which the termination measure is carried out on the system.

12.3. Service termination process

Service Users may request termination of their account using the account deletion function on the platform or by contacting Pebbles through the published support channels. On receiving the request, Pebbles:

• Verifies the information and the identity of the requester;
• Checks the status of the account;
• Confirms the termination of the account;
• Locks or removes access rights and the related functions;
• Handles personal data and account data in accordance with the Privacy Policy and the law on data retention.

Pebbles responds with the outcome of the request within 05 working days from the date of receipt of all information necessary to verify the request. Service Providers terminate services in accordance with the service partner contract.

12.4. Refunds on service termination

• Termination of a Pebbles account does not give rise to a right to a refund of amounts the User has paid for completed services, confirmed transactions or fees already incurred under the rules of Pebbles and/or the Service Provider.
• For service packages, membership programmes or paid services, refunds (if any) are made in accordance with the policy applicable to each specific package or programme, as published on the platform before the User enters into the transaction.
• Unless the law provides otherwise or the policy for a particular service provides for a refund, fees, charges, membership fees, registration fees or payments that have been used in whole or in part will not be refunded when the User terminates the account or ceases to use the platform.
• Refunds (if any) are made using the original payment method or another method notified by Pebbles, within the processing period set out in the corresponding payment policy or refund policy.

II. PROVISIONS ON THE CONTROL AND REVIEW OF INFORMATION ON THE PLATFORM

Pebbles establishes information control and review mechanisms to ensure that the information posted on the platform is accurate and consistent with the purpose of the services, and to limit false, fraudulent or discriminatory information and content that breaches the law. Control and review are carried out in respect of Service Provider information, Service User information, service listings, images, documents and other content posted or provided by users on the platform.

13. Information Control at Account Registration and Verification

13.1. For Service Users

This process collects information to serve the need to connect users with service delivery, ensuring strict compliance with personal data protection under Decree No. 13/2023/ND-CP.

Account registration/login

• Step 1: The user registers an account on the Platform by providing a telephone number or email address.
• Step 2: The user enters the confirmation code sent to their telephone number or email, and at the same time reads, considers and agrees to Pebbles' "Terms of Use" and "Privacy Policy" by selecting the confirmation function on the Platform to complete account creation.
• Step 3: Once registration is successful, the user may log in and use the Platform's functions, including searching for and booking services.

13.2. For Service Providers

To become a Service Provider on the Platform, a Service Provider must register an account in order to post service information to the Platform.

Account registration/login

• Step 1: On the homepage at https://provider.pebbles.vn/auth/sign-in, the Service Provider selects "Register for free".
• Step 2: Pebbles contacts the Service Provider to sign a Contract and issue an account. Pebbles requires the service provider to submit a business licence — a business household registration or enterprise registration — together with any conditional business licences. Pebbles verifies the accuracy of the information at the online lookup address of the Tax Department — Ministry of Finance: https://tracuunnt.gdt.gov.vn/tcnnt/mstdn.jsp
• Step 3: The Service Provider goes to https://business.uat.pebbles.vn/, enters the account credentials issued by Pebbles, then completes their profile and fills in all required information.

Verifying and updating Service Provider account information

• Step 1: On the homepage at https://business.uat.pebbles.vn/auth/sign-in, select "Register for free".
• Step 2: Pebbles makes contact to sign a Contract and issue an account; requires a business licence and any conditional business licences (if applicable); and verifies the information on the Tax Department lookup portal.
• Step 3: Go to https://business.uat.pebbles.vn/, enter the account credentials issued, and complete the profile.
• Step 4: In the administration page interface, the Service Provider selects "Services" on the control panel to create a new service.

13.3. Information control principles

The information and documents provided by Service Users and Service Providers are used within the scope necessary to:

• Authenticate accounts and identity;
• Verify the standing of Service Providers;
• Provide connection services;
• Prevent fake accounts, fraud and scams;
• Ensure the safety of Service Users and Service Providers;
• Perform obligations under the law.

Pebbles applies access control mechanisms, restricts direct access to the database and controls permissions on a need-to-know basis. Where registration information or verification records show signs of irregularity, inconsistency or falsification, or fail to meet requirements, Pebbles may require the user to supplement, amend or re-verify the information before continuing to provide the corresponding functions.

14. Management and Control of Service Information

14.1. General rules

Service Providers must comply with the following rules when providing service information:

• Service information may be given in only two languages: Vietnamese with diacritics or English. Information written in Vietnamese without diacritics, or written in Vietnamese but difficult to understand (unusual symbols or unusual fonts), will not be approved by the administration board.
• Illustrative images (if any) must be clear and of good quality. Listings will not be approved where the images:
  • Contain sensitive or obscene content, or content affecting fine customs and traditions;
  • Contain content relating to the denominations of currency in circulation;
  • Contain content that is irrelevant or is not a genuine image of the business;
  • Have been excessively edited or erased, so that the true condition of the business cannot be seen;
  • Have been downloaded from the Internet;
  • Contain suspicious hyperlinks, text, telephone numbers, etc.;
  • Are blurred, tilted, incorrectly oriented, composited from multiple images, or contain unusual characters or symbols intended to attract viewers' attention;
  • Are broken and do not display.
• Service listing title: must clearly state the service information and be distinguishable from other Service Providers already on the e-commerce floor, so as to avoid confusion. Service listing descriptions containing attention-grabbing terms such as "super hot" or "hot" will not be approved. Under Article 8, clause 11 of the Advertising Law, the terms "most", "only", "best", "number one" or terms of similar meaning may not be used (and if used, must be supported by documentary evidence).

14.2. Prohibited conduct

• The Pebbles Platform must not be used to propagate, advocate or solicit through unwholesome content.
• Language must be clear, plain and correctly spelled; all forms of slurred writing, chat-style abbreviations and obscure language are strictly prohibited.
• It is not permitted to post, or to use a signature that constitutes, advertising or solicitation drawing Service Users to other service sites. In the event of breach, Pebbles will immediately cease providing services.

In addition to the above, when transacting on the Platform, members must not engage in the following activities:

• Advertising that discloses State secrets or harms national independence, sovereignty, security or defence;
• Advertising that lacks aesthetic quality or is contrary to Vietnam's historical, cultural, moral traditions and fine customs;
• Advertising that affects urban aesthetics, traffic safety and order, or social safety;
• Advertising that adversely affects the dignity of the National Flag, National Emblem, National Anthem, Party Flag, national heroes, cultural luminaries, or leaders of the Party and State;
• Advertising of an ethnically discriminatory or racially discriminatory nature, infringing freedom of belief and religion, or embodying prejudice on grounds of gender or disability;
• Advertising that offends the reputation, honour or dignity of an organisation or individual;
• Advertising using an individual's image, words or writing without that individual's consent, except where permitted by law;
• Advertising that is inaccurate or misleading as to business capability or the ability to supply products, goods or services; or as to the quantity, quality, price, utility, design, packaging, trade mark, origin, category, method of service or warranty period registered or published;
• Advertising using direct comparison of the price, quality or effectiveness of one's own services with services of the same type of another organisation or individual;
• Advertising using the terms "most", "only", "best", "number one" or terms of similar meaning without lawful documentary evidence as prescribed by the Ministry of Culture, Sports and Tourism;
• Advertising with content constituting unfair competition under the law on competition;
• Advertising that infringes the law on intellectual property;
• Advertising that causes children to think, speak or act contrary to morality and fine customs, adversely affecting children's health, safety or normal development.

15. Mechanism for Reviewing and Controlling Posted Service Information

15.1. Implementation process

• Step 1: The Service Provider provides all required information: provider name, logo, cover image, additional provider introduction images, operating hours, tax code, date of commencement, telephone number, address, scale of operations, and the services delivered.
• Step 2: The information is content-moderated by the Platform Management Board before being officially published. Control and approval take place within 24 hours of the Service Provider submitting the information. The Management Board permits only listings meeting the prescribed standards to be displayed.
• Step 3: If the images, content and service information do not breach the general rules, do not breach the keyword rules or the Platform's posting criteria, and do not breach the law, the content management department will approve and publish the service information, at which point the service information is officially posted. In the event of a breach, the Management Board will require the Service Provider to amend that content and resubmit it for moderation.

15.2. Automated listing review and removal mechanism

Service listings and content posted by Service Providers are automatically screened by the system before display. The automated review mechanism uses keywords, content patterns and risk detection rules to identify:

• Advertising content, excessive claims or content misleading as to the service;
• Requirements for Service Users to pay fees, hand over money, purchase materials or make unusual payments in order to obtain the service;
• Content showing signs of "unrealistic guaranteed results", abnormal conduct or a service model showing signs of fraud;
• Content requiring Service Users to move to external communication channels such as Zalo, Telegram or similar methods in order to evade the platform's control mechanisms.

List of keywords refused/restricted when posting service listings:

Indicators of fraud:

• Requiring Users to pay fees, deposits, holding fees or other charges not transparently published on the platform;
• Providing false or misleading information about identity, legal status, professional qualifications, operating licences, the scope of services provided or service quality;
• Impersonating Pebbles, another Provider or a third party in order to collect information, receive payment or carry out fraudulent acts;
• Inviting Users to transact, pay or enter into agreements outside the platform in order to evade Pebbles' management, verification or complaint resolution mechanisms;
• Posting or sending links, QR codes, files, applications or content capable of creating security risks, unlawfully collecting personal information or misappropriating users' assets;
• Promoting, soliciting or carrying out investment, capital-raising, multi-level marketing, financial or other activities unrelated to the purpose of the Pebbles platform;
• Other conduct showing signs of fraud, deception, misappropriation of property or breach of the law.

Pebbles has the right to refuse to publish content, remove content, suspend or terminate accounts, and to cooperate with the competent authorities on detecting the above conduct. The keyword lists and detection rules are managed internally by Pebbles and updated regularly.

Handling flow when a prohibited keyword is detected:

1. When a Service Provider updates service information, the system automatically screens the listing title and content; if terms breaching the prohibited and restricted keyword lists are present, the system displays a warning together with the list of offending keywords.
2. The Service Provider selects "Close", reviews the content and removes the offending keywords before resubmitting the service listing for approval.
3. Where the Service Provider nonetheless proceeds to submit for approval: on the listing administration screen, the administrator receives information about the offending keywords, reviews it manually and sends a response requesting amendment of, or refusing, the service listing.
4. If the information still breaches the rules after resubmission, the Management Board has full discretion to remove that content and not publish it on the website, while notifying the Service Provider.

The Platform Management Board reserves full discretion to decide whether to retain or remove listings posted on this e-commerce trading floor without prior notice.

16. Operational Review and Handling

Where the system detects content showing signs of risk, the content may be temporarily hidden, restricted from display or referred for manual review. The platform management department carries out the review based on the service listing content, account information, activity history and related information. Depending on the outcome of the review, Pebbles may:

• Allow the content to continue being displayed;
• Require the Service Provider to amend or supplement the information;
• Temporarily hide or restrict display;
• Remove the service listing;
• Require additional documents for verification;
• Issue a warning or restrict certain account functions;
• Temporarily lock or terminate the account in cases of serious or repeated breach.

17. Review During Operation

Control is exercised not only at the time of posting but throughout the period the information exists on the platform. Pebbles may re-review a service listing where:

• The listing is updated or amended;
• The system detects signs of irregularity;
• A report or complaint is received from a Service User or another user;
• There is a request from a competent State authority;
• Information showing signs of a breach is discovered during operations.

Service listings that have expired or been removed, and accounts that have been terminated, are handled in accordance with the data retention policy and the relevant provisions of law.

18. Receiving Reports and Coordinated Handling

Pebbles provides a mechanism for Service Users and Service Providers to report information showing signs of inaccuracy, fraud, breach of the law or breach of the Operating Regulations. On receiving a report, Pebbles records it, checks the information and applies appropriate handling measures. Where there are signs of a breach of the law or the matter exceeds the platform's scope of handling, Pebbles coordinates with the relevant parties and the competent State authorities.

19. Recording and Ensuring Auditability

Key activities relating to accounts and content on the platform are recorded by the system through activity logs, including login information, administrative operations, and changes to and handling of content, within the technical scope of the system. Log information is used to support system security monitoring, event tracing, breach investigation and the handling of reports and complaints.

20. Plan for Receiving and Handling Service Information Inconsistent with What Was Published

Pebbles is a connection service platform; it does not directly provide, deliver or receive goods from Service Providers. Accordingly, where information or services posted are inconsistent with what was notified, published, presented or committed, Pebbles operates a mechanism for receiving reports and for checking and handling infringing information/service listings, in place of a mechanism for receiving and returning goods:

• Step 1 – Receiving the report: Service Users or users may report a service listing showing signs of being inconsistent with reality or with the published information, or showing signs of fraud, using the reporting function on the platform or the contact methods published by Pebbles. The report may concern: inaccurate service information; a scope of service or delivery conditions inconsistent with what was published; a service that does not exist; requirements for Service Users to pay money/deposits; or other content showing signs of a breach.
• Step 2 – Examination and verification: Pebbles records the report and checks the related information, including: the content of the service listing as posted; the Service Provider's account information; the history of edits, updates and related activity on the system; the verification documents provided; the correspondence, report and documents provided by the Service User; and other relevant information within Pebbles' control. Where necessary, Pebbles may require the Service Provider to explain, provide additional documents or re-confirm the service information.
• Step 3 – Applying interim measures: During verification, if a high risk or the potential for harm to Service Users is identified, Pebbles may temporarily hide the service listing, restrict access to it, or temporarily lock some of the functions of the Service Provider's account in order to prevent further transactions/connections arising.
• Step 4 – Acting on the outcome: Depending on the verification result, Pebbles may: allow continued display if the information is determined to be appropriate; require the information to be amended, supplemented or updated; temporarily hide or remove the service listing; issue a warning or restrict account functions; temporarily lock or terminate the account in cases of serious or repeated breach; and retain the related information and evidence to support the handling of complaints and disputes or requests from competent State authorities. Where signs of a breach of the law, fraud or conduct posing a risk of harm are identified, Pebbles takes appropriate handling measures and cooperates with the competent State authorities.
• Step 5 – Notifying the outcome: Once the review is complete, Pebbles responds to the reporter with the outcome, within the scope of information it is permitted to provide, and at the same time notifies or requires the Service Provider to remediate where the service information is determined to be inappropriate.

III. ALLOCATION OF RIGHTS AND RESPONSIBILITIES BETWEEN THE PLATFORM OWNER, SERVICE PROVIDERS AND SERVICE USERS

21. Rights and Responsibilities of the Owner of the Pebbles E-commerce Platform

a) Rights of the owner of the Pebbles E-commerce Platform

• To provide services to participating Members after they have completed the procedures and mandatory conditions set out by the Platform.
• To store Members' registration information and regularly update related changes and supplements.
• To develop service policies applicable to each category of user on the platform. These policies shall be published on the Pebbles E-commerce Platform.
• Where there are grounds to establish that a Member has provided inaccurate, misleading or incomplete information, or has violated the law or Vietnamese fine customs and traditions, the Platform has the right to refuse, temporarily suspend or terminate that Member's right to use the services.
• To immediately terminate a Member's right to use the services upon discovering that the Member has been convicted or is serving a sentence, where the Member's continued activity could expose the Platform to legal liability, or where the Member engages in fraud, impersonation, market disruption, conduct causing disunity among other Members, or activities violating the applicable laws of Vietnam.
• To remove listings, or edit or delete the content of information about those listings, upon discovering that the service information is not genuine or is fake.
• Where membership and the right to use the services are terminated, all rights granted to the Member shall automatically cease to be valid and be terminated, and any service information already posted shall also be taken down.
• To retain the copyright in the services and the content on the Platform in accordance with the laws of Vietnam on intellectual property protection. All logos and content in the various languages belong to the Platform. Any unlawful copying, use or dissemination of the above ownership rights is strictly prohibited.
• To reserve the right to change the service price list and payment methods during the period of providing services to Members (in the case of Service Providers) according to the Platform's needs and capabilities, giving those Members one (01) month's prior notice.

b) Obligations

• To moderate and publish Service Providers' service information on the Pebbles platform.
• To register the e-commerce service platform with the competent State authority.
• To comply with regulations on the protection of customers' personal information.
• To ensure the safety and security of Service Providers' payment transactions, to handle complaints and to compensate for damage where payment information transmitted through the e-commerce website is altered, deleted, destroyed, copied, disclosed, moved without authorisation or misappropriated, causing damage to Service Users.
• To provide information on business operations at the request of competent State authorities in order to serve e-commerce statistical work, inspection, examination and the handling of e-commerce violations.
• To store information on transactions carried out through the website in accordance with accounting law; and to fully discharge tax obligations as required by law.
• To comply with the Commercial Law and related legal provisions on promotional activities.
• To comply with regulations on the protection of users' personal information.
• To establish and publish on the website a mechanism for receiving and resolving customer complaints about service information.
• To develop and publicly announce the Operating Regulations, Rules and Guidelines on transaction processes for Members; and to monitor and ensure the implementation of those regulations on the Website.
• To fully publish information about the website owner on the website homepage in accordance with the law:
  • Entity name: PEBBLES VIETNAM COMPANY LIMITED
  • Tax code: 0319189328
  • Head office: Floors 17 & 18, The Nexus Building, No. 3A-3B Ton Duc Thang Street, Sai Gon Ward, Ho Chi Minh City, Vietnam
  • Telephone: +31654913649
  • Email: Info@Pebbles.vn
• To support Members in using the tools and features serving the conduct of transactions and the use of utility services on the Platform.
• To receive Members' feedback in the course of operations.
• To be responsible for building the platform: research, design, procurement of hardware and software, Internet connectivity, and the development of policies serving the Platform's operation, within permitted conditions and scope.
• To have inspection and supervision mechanisms to ensure that the information provided by Members on the system is accurate and complete.
• To publicly announce the mechanism for resolving disputes arising in the course of transactions. Where a Service User comes into conflict with a Service Provider or suffers harm to their lawful interests, the Platform must provide the Service User with information about the Service Provider and actively assist in protecting their lawful rights and interests.
• To use best efforts, within the scope and conditions available, to maintain the normal operation of the Platform and to remedy incidents: technical machinery faults, software errors, Internet transmission systems, personnel, social upheaval, natural disasters, power outages, and decisions of State authorities or a related third-party organisation. However, where such incidents occur beyond the Platform's control and constitute force majeure events causing damage to Members, the Platform shall not bear joint liability.
• To promptly handle matters upon discovering, or receiving reports of, business conduct on the platform that violates the law:
  • a) Prevent and remove from the website service listings that are not genuine or that are fake, in accordance with the law;
  • b) Remove service information that violates the law within a maximum of 24 hours from receipt of a request from the competent State management authority;
  • c) Cooperate with intellectual property right holders to review and remove products infringing intellectual property rights in accordance with the process and procedures published in the Operating Regulations;
  • d) Warn, or refuse to provide services on a temporary or permanent basis to, individuals, enterprises and organisations engaging in conduct that violates the law;
  • đ) Other measures under the Operating Regulations of the Pebbles E-commerce Platform.
• To assist State management authorities in investigating business conduct that violates the law, and in resolving disputes and complaints: providing information about entities showing signs of, or engaging in, conduct violating the law to the competent State management authority; regularly updating keywords as recommended by State management authorities and filtering information by keyword before information on goods and services is displayed on the website; and receiving and responding to information in order to resolve complaints, reports and disputes on the E-commerce Activity Management Portal of the Ministry of Industry and Trade (online.gov.vn).
• To require Service Providers to provide complete information, documents and relevant certificates proving they satisfy the conditions to operate when registering to use the services, in accordance with the laws of Vietnam.
• To store the registration information of enterprises, organisations and individuals participating in the Platform and to regularly update related changes and supplements.
• To establish a mechanism allowing enterprises, organisations and individuals participating in the Platform to carry out the service process on the platform.
• To apply the necessary measures to ensure the security of information relating to the business secrets of enterprises, organisations and individuals and the personal information of consumers.

22. Rights and Responsibilities of Service Providers

a) Rights

• To register, maintain, temporarily suspend or terminate a Service Provider account on the platform in accordance with the law and the Pebbles operating regulations.
• To create, post, edit, pause and manage service listings; and to choose the service delivery location, the scope of services and other service information suited to their needs.
• To use the functions, tools and support services provided by Pebbles.
• To request technical support from Pebbles and the receipt and resolution of reports, requests and complaints relating to the account, service listings and the use of services on the platform, in accordance with Pebbles' procedures.
• To have account information and data protected in accordance with the Privacy Policy and related legal provisions.
• To request the correction, updating or deletion of information within the scope permitted by law and in accordance with Pebbles' rules.

b) Obligations

• To provide complete, accurate and up-to-date information about the Service Provider, its legal representative, contact details and other information as required by Pebbles; and to be responsible for the accuracy, truthfulness and legality of the information provided.
• To provide truthful, complete and clear service information; and to ensure that the content of service listings corresponds to actual service capacity, without posting false or misleading information or content that breaches the law.
• Not to post content or use the platform to carry out unlawful service activities, fraud, misappropriation of property, collection of money contrary to the rules, or infringement of the lawful rights and interests of Service Users.
• Not to request, collect, use, store or share the personal data of Service Users beyond the necessary scope or contrary to the law on personal data protection.
• To keep confidential the information, records and data of Service Users accessed through Pebbles, and to use them only for the purpose of delivering lawful services.
• To fully discharge financial, tax and other obligations arising from their activities in accordance with the law.
• To proactively keep the account, login credentials and authentication methods secure; and to be responsible for activities carried out through the account, except where the fault is proven to lie with Pebbles.
• To cooperate with Pebbles in verifying information and handling reports, complaints, disputes, violations and requests from competent State authorities.
• To be responsible for the content of service listings, the information provided to Service Users and the service activities carried out through their account; and to compensate and bear responsibility in accordance with the law if they cause damage to Pebbles or Service Users.

23. Rights and Responsibilities of Service Users

a) Rights

• To register, maintain, temporarily suspend or terminate an account on the Pebbles platform in accordance with the law and the Pebbles operating regulations.
• To access the service information provided by Service Providers; and to select services suited to their needs, circumstances and means.
• To be provided with information about the service, the place of delivery, the conditions of delivery and other related information, within the scope of the information published by the Service Provider.
• To have personal information, records and data provided to Pebbles protected in accordance with the Privacy Policy and the law on personal data protection.
• To use the service-search functions and tools provided by Pebbles.
• To submit reports, requests and complaints relating to service listings, Service Providers or the use of services, and to have them received and handled by Pebbles in accordance with its rules.

b) Obligations

• To provide personal information and other necessary information completely, accurately and truthfully; and to be responsible for the information provided on the platform.
• To comply with the law, the operating regulations, the conditions of use and Pebbles' policies.
• Not to use the platform to provide false or fraudulent information, misappropriate property, disseminate unlawful content, or infringe the lawful rights and interests of Service Providers, Pebbles or other users.
• Not to use another person's account, not to provide or transfer the account for another person's use, and to be responsible for keeping their login credentials confidential.
• Not to collect, copy, use or share without authorisation the information or personal data of Service Providers, other users, or information accessed through the platform.
• To cooperate with Pebbles in verifying information and handling reports, requests, complaints, disputes and violations that arise.
• To be responsible before the law for the content of the information and records, and for the acts carried out, through their account.

24. Allocation of Responsibility for Resolving Issues Arising from Transactions

a) Limits on the responsibility of the Platform Management Board

Where any complaint or dispute arises in connection with transactions concluded on the Platform, Service Users and Service Providers are asked to notify the Platform administration board as soon as possible.

The Pebbles E-commerce Platform is responsible only for acting as an intermediary to receive information from Service Users and pass it to Service Providers, to conciliate between the two parties and to facilitate the process of resolving the matter between them (in the event of a dispute).

Where a dispute arises, the Company gives priority to negotiation and conciliation between the parties in order to maintain members' confidence in service quality. Any response concerning a dispute may be made directly at the head office of PEBBLES VIETNAM COMPANY LIMITED or by email/hotline. The resolution process follows the Dispute Resolution Mechanism published on the platform.

b) Allocation of responsibility for service outcomes

Service Providers are responsible for the outcome of the services and the process on the Pebbles E-commerce Platform. Where a Service User has questions about such outcomes, the Service User is asked to contact the Service Provider directly or to contact the Platform Management Board for resolution.

IV. APPLICABLE PROVISIONS

The Regulations of the Pebbles E-commerce Platform take effect from the date of signing of the Decision issuing them together with these Regulations. The Platform has the right to amend the Regulations by giving notice on Pebbles to its members. Amended Regulations take effect from the date on which the Decision amending the Regulations takes effect. A member's continued use of the services after the amended Regulations are published and implemented constitutes acceptance of those amended Regulations.

The Operating Regulations will be updated and supplemented by Pebbles on an ongoing basis in line with actual operations and applicable law, and will be publicly announced 07 (seven) days in advance on the platform before official application. Members participating in the Platform are responsible for complying with the Regulations in force when transacting on the e-commerce service platform.

V. COMMITMENT PROVISIONS

All members transacting on the Pebbles E-commerce Platform undertake to accept, implement and comply with the content of these Regulations.

For any questions, customers/partners are asked to contact the Management Board of the Pebbles E-commerce Platform using the details below:

Official contact address: Pebbles e-commerce service platform

• Company: PEBBLES VIETNAM COMPANY LIMITED
• Address: Floors 17 & 18, The Nexus Building, No. 3A-3B Ton Duc Thang Street, Sai Gon Ward, Ho Chi Minh City, Vietnam
• Hotline: +84 901 345 874
• Email: Info@Pebbles.vn