CarDoctor Vendor’s Privacy Policy

PRIVACY POLICY

The Vendor Website/App is designed to support Sellers (Vendors) in managing their storefronts, uploading product listings, tracking orders, updating shipping status, coordinating with Express service providers, and conducting other business activities in the online environment. This platform enables Sellers to operate conveniently and synchronize data directly with the CarDoctor Garage V2 e-commerce marketplace, ensuring smooth and transparent operations.

As the Vendor Website/App operates in synchronization with and is integrated into the CarDoctor Garage V2 marketplace, Sellers using this platform agree to comply with all policies and regulations issued by the marketplace. Use of the Vendor Website/App constitutes the Seller’s confirmation that they have read, understood, and agreed to comply with all such rules, to ensure consistency, transparency, and efficiency in transaction activities on the CarDoctor Garage V2 marketplace.

1. Introduction to the CarDoctor Vendor Website/App

Welcome to the Privacy Policy of the CarDoctor Vendor platform operated by Car Doctor Vietnam Joint Stock Company (hereinafter collectively referred to as “CarDoctor” or “we/us”). CarDoctor Vendor allows participants to create an account to enter into contracts, whereby users may communicate, buy and sell automotive-related products and services (including exchanging, transmitting, linking, and interacting with the CarDoctor Garage V2 e-commerce marketplace).

CarDoctor strictly fulfills its obligations regarding information security in accordance with Vietnam’s regulations on Personal Data Protection and is committed to respecting the privacy rights of all users of our mobile application.

In the course of using our Services, users will agree to provide and/or generate the information and data necessary to serve the purposes specified in Article 4 of this Privacy Policy. We understand that the personal data you entrust to us is extremely important. Therefore, we commit to responsibly managing, safeguarding, and processing such information appropriately.

This Privacy Policy (“Policy”) is established to help you understand how we process the personal data that you have provided, generated, or that we currently store and/or may store in the present and/or in the future.

2. General Provisions

a. Definitions

  • “Platform” means the mobile application system developed by CarDoctor.

  • “Services” means the collective term for the Platform and the services we provide as described on our Platform.

  • “Personal Data” means the data and information of users participating in the Platform as described in Article 3 of this Policy. Personal data is information in the form of symbols, letters, numbers, images, sounds, or similar forms that helps identify a specific person.

  • “Processing of Personal Data” means one or more operations performed on personal data, such as: collecting, recording, analyzing, verifying, storing, amending, publicly disclosing, revealing, combining, accessing, retrieving, recovering, encrypting, decrypting, copying, sharing, transmitting, providing, transferring, deleting, destroying personal data, or other related actions.

  • “User” means an individual who registers an account with us to use the Services, including Suppliers, Partners, and Customers. Users may collectively be referred to as “you.”

  • “Supplier” means entities that provide spare parts, accessories, and other automotive-related products and services.

  • “Partner” means entities participating in our Platform to provide services supporting Suppliers and Customers in establishing, performing, and completing transactions. Such entities include but are not limited to: payment intermediaries; shipping carriers; logistics service providers; and other entities approved by CarDoctor.

  • “Customer” means an organization or individual who has demand for using our Services, through which the Customer may purchase automotive-related goods and services offered on the Platform.

b. General terms

  • The contents of this Privacy Policy and its updates from time to time apply to all users of the Platform.

  • Personal Data is stored on CarDoctor’s servers in accordance with applicable law. We commit to making reasonable efforts to apply appropriate measures to keep Personal Data confidential and protected against unauthorized access.

  • By registering an account and selecting “agree” to this Privacy Policy, the User agrees to the terms of this Policy when using the Platform. At the same time, the User acknowledges that they understand and agree to the privacy policies of CarDoctor’s partners and affiliates in cases where the Platform is linked to other systems.

  • We may update this Privacy Policy from time to time. Any changes will be notified to you via the Platform. You agree that it is your responsibility to regularly review and check this Policy to be aware of any updates or changes before deciding to continue using the Platform.

  • Users agree not to provide any inaccurate or misleading information and agree to notify CarDoctor of any inaccurate information or any changes. CarDoctor reserves the right, at its sole discretion, to request additional documents as necessary to verify any information provided by the User.

  • Selecting or not selecting “agree” to this Privacy Policy at the time the User registers an account, accesses the Platform, or when notified by CarDoctor about the Privacy Policy constitutes the User’s request to register for or not to use the Platform Services. If the User does not agree with any terms of this Policy, please stop using the Services or contact us for support.

  • If you discontinue using our Platform, or your right to use the Platform and/or Services is terminated or canceled, we may continue to store, use and/or disclose your Personal Data in accordance with this Policy and our obligations under applicable laws on personal information confidentiality. Subject to the law, we may securely destroy your Personal Data without prior notice to you.

  • We reserve the right to refuse deletion or destruction of data where your request is not compliant with applicable law, or although compliant, falls within circumstances where we are not permitted to delete or destroy under relevant legal provisions.

  • Other rights and obligations of Data Subjects, Data Controllers, Personal Data Processors, Data Controllers and Processors, and third parties are set out in detail in this Privacy Policy.

3. Organizations and Individuals Processing Personal Data

  • Personal Data Controller and Processor: Car Doctor Vietnam Joint Stock Company.

  • Personal Data Processor: Suppliers and Partners authorized by CarDoctor to use a portion of Personal Data within the scope of their purposes and functions to facilitate users’ transactions and comply with relevant legal regulations.

  • Other organizations and individuals who, under relevant laws, are entitled to process Personal Data.

4. Time of Collection and Types of Personal Data Processed

a. Types of Personal Data processed

The types of Personal Data processed include basic personal data and sensitive personal data as prescribed by the laws on Personal Data Protection, including but not limited to:

  • Information used for identification, relating to, describing, or reasonably linkable to you (including biometric data).

  • Personal Data collected when the User consents to provide it.

  • Personal Data including full name, gender, date of birth, nationality, contact information, phone number, mailing address, email address, etc.

  • Personal Data generated during activities on the Platform, including but not limited to images, videos, and communications between Users before, during, and after using the Services.

  • Payment data, including bank card details, credit card details, bank accounts, payment accounts, payment history, paid transactions, goods and services paid for, etc.

  • Data provided through User feedback, survey results, when receiving marketing information from us, User interests, conversations, emails, call history on the Platform between Users or with any other parties (if any).

  • Data about persons, accounts, topics, and content to which the User connects, and how the User interacts with, uses, and operates on our Platform or other applications linked to the Platform.

  • Data provided by others about the User, such as content, contact information, and information others provide when using our Platform. This may include information about the User, such as photos containing the User or the User’s contact details shared by others.

  • Location data collected as provided by the User or from the User’s device when accessing and using our Platform, such as GPS location.

  • Data collected from the User’s devices and linked applications used in connection with Platform activities, data from the User’s personal accounts, or data on the User’s device if the User chooses to upload, synchronize, or import such information from their device. We collect information from computers, phones, and other devices connected to networks used by the User to integrate with our application.

    • Device attributes: operating system, hardware version, software, battery level, signal strength, available storage, plugins, browser type, and file/app names and types.

    • Device activity: information about actions and behaviors performed on the device, such as whether a window is in the foreground or background, or mouse movements.

    • Device settings data: information the User allows us to collect when the User permits device data synchronization, such as address book, contacts, call logs, SMS logs, photos, videos, etc.

  • Cookie data: Cookies are small text files (typically containing letters and numbers) placed in a browser’s or User’s device memory when visiting a website or viewing a message. Cookies enable us to recognize a specific device or browser. Cookies cannot read information on the User’s hard drive or cookie information sent by other websites. Cookies are harmless to the User’s system. Users may refuse or accept all cookies sent.

  • Network and connection: information such as mobile carrier or ISP name, language, time zone, mobile phone number, and information automatically generated when the User uses the Platform such as IP address, cookies, website logins, etc.

  • Other information that is provided, transferred, created, sent to, reflects, or relates to the User, directly or indirectly, during use of or interaction with the Platform, other Users, or our Partners.

The foregoing is not intended to be an exhaustive list and only provides some common examples of the types of Personal Data that may be collected.

b. Collection circumstances

We will or may collect Users’ Personal Data when Users register for and/or use our Services and Platform; and when Users interact with the Platform, other Users, or Partners approved by us to participate on the Platform.

c. Collection from other sources

We may collect your information from you, affiliated companies, third parties, and other sources, including but not limited to business partners (e.g., logistics and payment service providers), credit rating agencies, advertising and referral service providers, loyalty programs, other Users of our Services, publicly available data sources, or government data sources.

d. Data of other individuals

In some cases, you may provide us with personal data of other individuals (e.g., family members, friends, or persons in your contact list). If you provide us with their personal data, you represent and warrant that you have obtained their consent for us to process such personal data in accordance with this Policy.

5. Purposes and Methods of Processing Personal Data

a. Purposes of processing

Users agree that we may use the Personal Data specified in Article 4 for the following purposes:

  • Provision of suitable Services: to personalize the Services, connect you with the most suitable Users for your needs at the most reasonable price and timeframe; and to enforce the Terms of Service/marketplace operating regulations or any other agreements between the parties.

  • Supporting Users in establishing, performing, and terminating transactions: to review and/or process your applications/transactions with us or your transactions/correspondence with other Users and third parties; to administer, operate, provide, and/or manage your use of and/or access to our Services and Platform; and to respond to, handle, resolve, or complete a transaction and/or fulfill Users’ requests for specific products and services.

  • Partners’ financial or credit services: to evaluate and make decisions relating to your credit profile and risk and eligibility for loans, pay-later, or credit products (if any); and to provide necessary information for you to register for Partners’ services via online connections.

  • Logistics services: to enable logistics Partners to support transactions for delivery of goods from Suppliers to Customers or vice versa; to collect and disburse cash-on-delivery (COD) amounts and shipping fees, COD fees, and other service fees (if any); to resolve disputes and complaints relating to services; and other logistics-related activities.

  • Other transaction support services: to enable Partners providing other transaction support services to participate in servicing transactions between Suppliers and Customers, before, during, and after completion; and to support part or all of the process of buying and selling goods or providing services, from displaying and introducing goods/services to contract formation, service provision, payment, and after-sales services.

  • Enhancing service quality: to assess service quality and your needs to develop, modify, and upgrade Services on the Platform.

  • Understanding User experience and improving the application: to better understand User experience, improve the Platform quality, identify trends of User interest, obtain a more complete view of needs and preferences, thereby enabling us to approach Users more effectively to improve service quality and upgrade the application for the most convenient experience.

  • User support and care: to help resolve issues encountered during Platform use; to use email or phone number to notify Users about products, services, application updates, and new information relating to matters of interest.

  • Marketing and advertising: to derive additional characteristics related to Users based on Personal Data provided (to us or third parties); to deliver relevant information, products, and services (provided by us/Suppliers/third parties); and/or to provide programs, offers, communications, and advertising campaigns sent to you via various media and communication methods, marketing and promotional information and materials relating to products and/or services (including but not limited to third-party products/services with which we may cooperate or affiliate), whether existing now or developed in the future.

  • Measurement, analytics, and other business services: to analyze how you use our Platform, such as content viewed or interacted with, features used, actions taken, persons or accounts interacted with; and timing, frequency, and duration of Customer activity, to provide metrics on satisfaction, service feedback, and interest trends.

  • Safety, security, and integrity: to verify accounts and prevent harmful conduct, detect and prevent spam and impersonation and other negative experiences, maintain Platform integrity, and enhance safety and security both on and off the Platform; including investigating suspicious activity/policy violations or identifying when someone may need assistance.

  • Communications with Users: to send marketing information and notifications relating to our Services and Platform; to respond to Users’ inquiries; and to allow other Users to interact with or contact you or see certain activities on the Platform, including notifying you when another User sends you a private message or posts comments about you on the Platform, or linking to your use of Platform features.

  • Legal and operational purposes: (i) identifying Users for fraud detection; (ii) handling complaints, feedback, sanctions, and remediation related to any content Users participate in on the Platform; (iii) statistics and research for internal and legal reporting and/or record retention requirements, compliance with requests from competent authorities; (iv) protecting the safety of Users or others, safeguarding rights and obligations of relevant parties, and ensuring legal compliance.

  • Any other purposes for which we notify Users at the time we seek Users’ consent.

b. Methods of processing

  • Method of collection: as specified in Article 4 of this Privacy Policy.

  • Method of storage: Personal Data is stored on CarDoctor’s servers and in CarDoctor’s customer database systems, or wherever we or our branches, subsidiaries, affiliates, partners, or service providers have facilities, and may be backed up to data centers in other regions.

  • Transfer/sharing: We will apply necessary security measures to ensure the safe transfer/sharing of Users’ Personal Data without data leakage, and require recipients to implement appropriate data security measures.

  • Analysis: Personal Data analysis is performed in accordance with CarDoctor’s internal procedures. We maintain strict supervision over each analysis process, including verifying compliance with legal requirements on data protection and ensuring information security of IT systems prior to analysis. We also apply strict rules to ensure personal information is anonymized or de-identified at appropriate stages in the processing.

  • Encryption: Collected Personal Data is encrypted according to appropriate encryption standards when necessary during storage or transfer to ensure data is protected, authenticated, integral, and cannot be altered after transmission.

  • Access, correction, deletion, destruction: in accordance with this Privacy Policy.

6. Duration of Protection and Processing of Personal Data

a. Data is protected from the time you begin registration for or access to the Platform. We apply various security measures and strive to ensure the safety of Personal Data.

b. Personal Data is processed from the time we receive Personal Data provided and/or generated by the User and we have an appropriate legal basis for processing in accordance with law.

c. Until the User requests deletion or destruction of Personal Data in accordance with personal data protection laws and other relevant regulations, or until we have reasonable grounds to determine that retaining such Personal Data no longer serves the purpose for which it was collected.

7. Data of Children and Minors

a. In all cases, Users must ensure they are at least 18 years old when providing and using any of our Services. Users must ensure that no person under 18 is allowed to use their account to conduct any activities on the Platform.

b. We do not knowingly collect or retain any Personal Data or any non-personally identifiable information of anyone under 18 years old. If the User violates the requirement in item (a), resulting in the Personal Data of a person under 18 being processed, the User shall bear full responsibility toward relevant parties. CarDoctor shall be exempt from any liability related to the User’s violation.

c. We reserve the right to lock accounts, delete Personal Data that violates this Article, and apply applicable penalties in effect from time to time.

8. Data Protection with Third Parties

During use of the Platform, you agree that we may share your Personal Data with third parties in the following cases:

a. We may engage service providers or business partners to perform certain activities related to the Platform such as repair, maintenance, upgrades, development, and expansion. We require such third parties to comply with all Personal Data protection requirements under applicable law.

b. We may share, use, process, disclose, and/or transfer your Personal Data to third parties, agents, and/or our affiliates or related companies, and/or other third parties in Vietnam or outside Vietnam, for one or more of the purposes stated above, in accordance with procedures and regulations under applicable law. Such third-party service providers, agents, affiliates, related companies, and/or other third parties will process your Personal Data on our behalf or vice versa for one or more of the stated purposes. Such third parties include:

  • Our parent companies, subsidiaries, affiliates, and related companies;

  • Users with whom you have transacted or interacted on the Platform or in connection with your use of the Services for the purposes stated above;

  • Other users of our Platform for one or more of the purposes stated above;

  • Contractors, agents, service providers, and other third parties whom we engage to support or supplement our business operations, including but not limited to administrative service providers, postal companies, telecommunications companies, advertising and media partners, IT companies, e-commerce organizations, and data centers;

  • Third parties to whom we disclose information for one of the stated purposes, and such third parties in turn collect and process your Personal Data for one or more purposes.

c. Sharing data with other Users: CarDoctor facilitates communication between Suppliers and Customers and may share a User’s contact information (e.g., name, phone number, email, etc.) with other Users to: (1) facilitate or notify the resolution of complaints or disputes relating to or arising from interactions among two or more Users of the Platform; or (2) facilitate the provision of Services.

d. Legal requirements: We may disclose Personal Data as required by law or by competent state authorities.

e. Business transfers: In the event of a merger, consolidation of all or part of our business with another company, a potential investor or an investor who has completed acquisition procedures may access, process, and use information we store and maintain, including Users’ personal information. We require such third parties to comply with all Personal Data protection requirements under applicable law.

9. Operational Data Security

a. CarDoctor applies necessary technological measures to ensure the security of Personal Data against unauthorized access to the system.

b. CarDoctor ensures operational security: we store Users’ Personal Data in a secure operating environment and allow only CarDoctor employees and representatives to access personal information, solely on a need-to-know basis for their work, and subject to confidentiality obligations under law and contracts between them and CarDoctor.

c. If CarDoctor’s servers are attacked resulting in disclosure or loss of Users’ Personal Data, we shall coordinate with competent authorities to investigate and promptly handle the incident and notify Users.

10. Access, Modification, and Update of Users’ Personal Data

a. Users always have the right to access their personal information during Platform use. If information is incorrect or inaccurate, Users may update, change, or delete such information, except for information we are required to retain by law or to ensure legality, operations, and transaction performance on the Platform. When updating personal information, CarDoctor may require Users to verify their identity before processing the request.

b. If direct editing is not possible due to technical or other reasons, Users should contact us to request modification of their Personal Data.

c. We may refuse unreasonable repetitive requests requiring disproportionate technical efforts, posing risks to others’ privacy, or being impractical (e.g., changing phone number information more than three (03) times per day).

d. We may provide access and correction free of charge unless it requires disproportionate effort. If the User’s request exceeds the free scope, we may charge a reasonable fee to handle and process the request. In such case, we will notify the estimated fee before you agree to proceed.

11. Cross-Border Transfer of Users’ Information

Users’ information and/or Personal Data may be transferred abroad, stored, or processed outside the User’s country for one or more purposes. CarDoctor will only transfer Users’ Personal Data abroad in accordance with this Privacy Policy and applicable laws on Personal Data protection.

12. Withdrawal of Consent; Requests to Restrict Processing; Objection to Processing; Requests for Provision of Personal Data; Access or Correction

a. Withdrawal of consent; restriction/objection requests

Users may withdraw consent, request restriction, or object to the collection, processing, use, and/or disclosure of Personal Data held or controlled by CarDoctor by changing permissions on their personal device or by emailing/notifying CarDoctor. We will handle such requests in accordance with this Privacy Policy and applicable law. However, withdrawal of consent or restriction/objection may mean we can no longer provide Services to the User, and we may need to terminate the existing relationship and/or any contract between the User and/or us, other Users, or relevant Partners/third parties.

b. Requests for provision of Personal Data

Users have the right to request CarDoctor to provide their Personal Data to them by sending an email or notification to CarDoctor. Users also have the right to request CarDoctor to provide Users’ Personal Data to other organizations/individuals, or to provide other organizations’/individuals’ Personal Data to Users, provided that Users furnish valid authorization or other documents evidencing the data subject’s consent as required by law.

A User’s request is only considered valid and will be accepted for processing when all necessary information is provided and the correct forms prescribed by current law are used.

CarDoctor may charge a fee to handle and process the request for provision of Personal Data. If a fee applies, CarDoctor will notify the User in writing of the estimated fee depending on the specific case.

Where a User’s request is valid under law and falls within cases where CarDoctor is permitted to provide the data, CarDoctor will notify the User via appropriate communication methods of the time, place, method of provision, cost (if any), payment method, and payment deadline (if any), and will provide the Personal Data accordingly and follow other legal procedures.

CarDoctor notes that CarDoctor is not obligated to fulfill or handle a request for provision of Personal Data unless the User has agreed to pay the fee as notified in point (c) above.

c. Requests to access or correct Personal Data

If the User has registered an account with CarDoctor, the User may access and/or correct Personal Data held or controlled by CarDoctor through the Account Settings page on the Platform. If the User has not registered an account, the User may request access and/or correction by submitting a written request to us. CarDoctor will need sufficient information to verify the User’s identity and understand the nature of the request; therefore, please submit your written request by email or notification to CarDoctor.

CarDoctor may charge a fee to handle and process access requests. If a fee applies, CarDoctor will notify the User in writing of the estimated fee depending on the specific case. Please note that CarDoctor is not obligated to fulfill or handle access requests unless the User has agreed to pay the fee.

13. Complaint Handling Mechanism

a. Any complaint related to the risk of Personal Data disclosure or misuse beyond the stated collection purposes or usage scope may be submitted via our online chat function or through our publicly disclosed contact information.

b. Our staff will receive Users’ complaints and, depending on the nature and severity of the inquiry or complaint, we will implement specific measures to address it.

14. Data Protection, Limitation of Liability, and Potential Unintended Consequences/Damages

a. Commitment to protection of Personal Data: We commit to fully performing our obligations under applicable laws on Personal Data protection. We apply appropriate technical and organizational measures to ensure the security of personal data we collect, store, process, and control, in accordance with relevant legal instruments. However, we do not guarantee and shall not be liable for the security of personal information you provide on third-party platforms, websites, or applications outside our control.

b. Third-party services and external links: To enhance user experience and value, our Platform may integrate with, link to, or connect with websites, applications, and services managed or operated by third parties. Such third parties have separate privacy policies and data processing mechanisms independent from us. Linking does not mean we control, co-manage, or assume responsibility for the operation, content, privacy policies, or data collection/processing practices of such third parties. Data collected or processed by linked partners (including affiliate marketing or commercial partners) through the Platform may fall outside our control or storage.

c. Potential unintended consequences/damages:
We apply multiple security technologies and access controls to protect Users’ Personal Data from unauthorized access, use, disclosure, or sharing. However, we cannot guarantee absolute security in situations including but not limited to: software or hardware incidents during data processing leading to loss or leakage of Personal Data; security vulnerabilities beyond our reasonable control, including targeted cyberattacks (e.g., hacker attacks) resulting in information leakage.

Where Users use artificial intelligence features (AI assistant/advisory assistant) on the Platform: the AI tool is programmed based on algorithms and data trained by us, combined with data provided by Users, to generate assessments, comments, advice, and responses. The information provided by AI is for reference only, and Users must exercise judgment and bear responsibility for their final decisions.

Biometric data is sensitive personal information and cannot be changed if leaked. Collecting and processing such data may involve risks such as identity impersonation, loss of control over personal information, unauthorized access, or misuse. Although we apply strict security measures, absolute safety cannot be guaranteed in all circumstances.

Users are responsible for safeguarding authentication information related to their accounts, including login passwords, OTP codes, and other verification methods. Sharing authentication information with any third party entails risks of unauthorized access, and we shall not be liable in such cases.

Where Users voluntarily disclose or publicly share personal data (e.g., via comments, reviews, or other public interactions), such data may be collected and used by third parties for purposes beyond the control of Users and us. Users should be fully aware of this risk before publicly sharing personal data.

We recommend that Users proactively safeguard their personal devices (including mobile phones, tablets, personal computers, etc.) during Platform use. Users should log out after each session and avoid leaving devices logged in when not in use to reduce risks of unauthorized access.

We emphasize that transmitting Personal Data over the internet inherently involves risks of interception or unauthorized access. Therefore, Users should access the Platform only via secure devices, applications, and connection systems, and are responsible for maintaining confidentiality of login information on each platform they use.

d. Disclaimer of liability: We shall not be legally liable for any loss, damage, or risk relating to Personal Data in the following cases:

  • Users voluntarily publish, share, or disclose personal information to third parties or in public areas;

  • Information leakage due to Users’ endpoint devices, networks, or software being attacked or infected with malware;

  • Users breach confidentiality obligations, share accounts, unlawfully use others’ personal information, or fail to comply with our Terms of Use;

  • Cybersecurity incidents beyond our reasonable control, including but not limited to sophisticated targeted attacks (APT, DDoS, etc.) despite implementation of protective measures as required;

  • Provision of personal information in response to lawful requests from competent state authorities;

  • Users use third-party services, tools, or platforms not provided or managed by us.

e. Users’ responsibilities: Users are responsible for protecting their personal information, account information, and access devices. Providing information to third parties or using services outside our management is at Users’ discretion and responsibility. Users also must ensure the information provided to the Platform is accurate, complete, and promptly updated.

15. Effectiveness of the Privacy Policy

a. This Policy takes effect from January 16, 2025 until replaced by an updated version.

b. This Policy shall be construed and governed in accordance with the laws of Vietnam.

c. This Policy may be amended from time to time depending on actual circumstances. Any future changes will be notified to Users via the Platform. By continuing to use the Platform after updates are made, Users are deemed to have agreed to and committed to comply with the updated content in full.

BY CHECKING “I AGREE”, THE USER CONFIRMS THAT THEY HAVE READ, FULLY UNDERSTOOD, AND COMMIT TO COMPLYING WITH THE ENTIRE CONTENT OF THIS PRIVACY POLICY. THIS ELECTRONIC CONFIRMATION CONSTITUTES A LEGALLY BINDING AGREEMENT BETWEEN THE USER AND THE COMPANY, HAVING THE SAME LEGAL EFFECT AS A HAND-SIGNED CONTRACT.