Vietnam Regional Service and Creator Notice

Effective Date: 14 July 2026

Last Updated: 14 July 2026

Version: 1.0.0

This Vietnam Regional Service and Creator Notice (the “Vietnam Regional Notice”) provides additional terms and information concerning the availability and operation of Fraw in Vietnam.

This Vietnam Regional Notice applies to individuals located in Vietnam who access or use the Fraw mobile application, website, software, official functions, extensions, creator tools, and related services, collectively referred to as the “Service.”

The Service is operated by Untitled Labs Limited (“Fraw,” “we,” “us,” or “our”), a company incorporated in Hong Kong.

This Vietnam Regional Notice supplements and should be read together with:

the Fraw Terms & Conditions;
the Fraw Privacy Policy;
the Fraw Vietnam Privacy Addendum;
the Fraw Creator & Diamonds Policy;
the Fraw Cookie Policy or any replacement Cookies and Similar Technologies Policy;
any applicable purchase, subscription, community, content, referral, or promotional rules; and
notices presented through the Service.

Capitalized terms not defined in this Vietnam Regional Notice have the meanings given in the Terms & Conditions, Privacy Policy, Vietnam Privacy Addendum, or Creator & Diamonds Policy.

If this Vietnam Regional Notice conflicts with the global Terms & Conditions or Creator & Diamonds Policy, this Vietnam Regional Notice will apply to users and creators in Vietnam to the extent:

Fraw expressly states that a Vietnam-specific rule applies;
a function is unavailable or restricted in Vietnam;
the conflict concerns a Vietnam-specific legal or regulatory requirement; or
applicable Vietnamese law requires a different result.

Nothing in this Vietnam Regional Notice limits any right or protection that cannot lawfully be excluded, restricted, or waived.

1. Purpose of this Vietnam Regional Notice

This Vietnam Regional Notice explains:

which parts of the Service may be available in Vietnam;
how regional restrictions may affect access;
how Fraw may separate private and public functions;
when account or phone-number verification may be required;
how Published Extensions may be reviewed, restricted, or removed;
additional responsibilities of creators in Vietnam;
how Vietnamese content and online-information requirements may apply;
whether Diamond earning or withdrawal is available;
how subscriptions, credits, and top-ups operate;
how users may report unlawful or harmful content;
how Fraw may respond to lawful governmental or regulatory requests; and
how Fraw may modify or discontinue functions in Vietnam.

The availability of the Fraw application for download through an app store does not mean that every function described in the global Terms or Creator Policy is available in Vietnam.

2. Applicable Vietnamese framework

Depending on the nature, scale, and operation of the Service, Fraw’s availability in Vietnam may be subject to laws and regulations concerning:

personal-data protection;
cybersecurity;
management of Internet services and online information;
cross-border digital services;
electronic transactions;
telecommunications;
consumer protection;
e-commerce;
advertising;
intellectual property;
image and personality rights;
child protection;
taxation;
payments and foreign exchange;
prohibited or unlawful online content; and
requests from competent authorities.

Vietnam’s Law No. 91/2025/QH15 on Personal Data Protection was issued on 26 June 2025 and took effect on 1 January 2026. Fraw’s handling of personal data relating to users in Vietnam is further described in the Vietnam Privacy Addendum.

Vietnam’s Decree No. 147/2024/ND-CP concerning the management, provision, and use of Internet services and online information took effect on 25 December 2024. Depending on how the Service and its public functions are classified, requirements concerning account authentication, online information, public content, content removal, reporting, and platform responsibility may apply.

Fraw may change the availability or operation of the Service where reasonably necessary to comply with changes in Vietnamese law, regulatory interpretation, official directions, app-store requirements, or operational conditions.

3. Regional availability does not guarantee every feature

Fraw may make the application available for download in Vietnam while enabling, restricting, delaying, or disabling particular functions.

Availability for download does not guarantee that users in Vietnam may access:

every AI model;
every generation type;
every official function;
every public extension;
creation of private extensions;
publication of extensions;
public creator profiles;
creator rankings;
recommendations or discovery;
Diamond earning;
creator withdrawals;
every subscription or top-up option;
every payment or payout provider;
referral programs;
promotional campaigns; or
any future feature.

Features may be limited according to:

account tier;
age;
account status;
verification status;
device or operating system;
app-store channel;
location;
legal or regulatory requirements;
content category;
provider availability;
payment support;
technical readiness;
moderation capacity; or
Fraw’s reasonable assessment of risk.

Fraw may operate different feature configurations for Vietnam without providing the same configuration in every other market.

4. Initial Vietnam service configuration

Unless Fraw states otherwise in the Service, Fraw may initially make the following functions available in Vietnam:

4.1 Core and private functions

Fraw may enable:

account creation;
account authentication;
core AI image generation;
official generation functions;
Rebuild;
Blend;
subscriptions;
credit purchases or top-ups;
private gallery storage;
deletion of eligible gallery items;
account deletion;
creation of private extensions for eligible subscription tiers; and
use of other private functions expressly made available.

4.2 Public and creator functions

Fraw may separately enable, restrict, delay, or disable:

browsing Published Extensions;
using Published Extensions;
publishing extensions;
public creator profiles;
creator discovery;
extension rankings;
public sharing;
Diamond earning;
withdrawal requests;
creator payouts; and
commercial or promotional creator activity.

A user may have access to core generation without having access to public publication, Diamond earning, or withdrawals.

5. Account registration and authentication

Fraw may permit users in Vietnam to create an account through:

Apple ID;
Google login;
another authentication provider;
an email-based method;
phone-number verification; or
another method made available by Fraw.

The availability of Apple or Google login does not guarantee that those methods alone will satisfy every authentication requirement applicable to public publication or distribution of information in Vietnam.

Vietnamese authorities have stated that domestic and cross-border social-media platforms subject to Decree No. 147/2024/ND-CP must authenticate relevant user accounts through Vietnamese mobile-phone subscriber information, and that authenticated accounts are required for specified public posting or sharing functions. Whether these requirements apply to Fraw depends on the legal classification and actual operation of Fraw’s public features.

Fraw may therefore require additional verification before allowing a user to:

publish an extension;
make a creator profile public;
share information publicly;
distribute reusable content;
earn Diamonds;
request withdrawal;
participate in a creator campaign; or
access another regulated public function.

6. Vietnamese phone-number verification

Where Fraw determines that Vietnamese phone-number verification is required or reasonably appropriate, Fraw may require a user to provide and verify a Vietnamese mobile-phone number.

Verification may involve:

entry of a phone number;
receipt of a one-time password;
confirmation through a telecommunications or verification provider;
checking the country calling code;
checking verification status;
recording the time of verification;
limiting failed verification attempts;
fraud and abuse checks; and
periodic re-verification.

Fraw may use a third-party provider to perform phone verification.

Fraw does not guarantee that:

every Vietnamese phone number can be verified;
every telecommunications provider is supported;
verification will always succeed;
one verification will remain valid indefinitely; or
phone verification alone will satisfy every legal requirement.

If verification fails, expires, is withdrawn, or appears fraudulent, Fraw may:

deny public publication;
restrict public sharing;
disable creator functions;
suspend Diamond earning;
prevent withdrawal;
require re-verification; or
restrict other functions reasonably connected with the verification requirement.

Private generation functions may remain available where permitted, even if public publication is restricted.

7. Classification of public Fraw features

Fraw is primarily an AI creative service. It is not intended to operate as a general-purpose social network unless Fraw expressly introduces and supports such functionality.

However, some Fraw functions may have characteristics associated with an online content platform because users may be able to:

maintain a creator identity;
publish extension titles and descriptions;
publish example or reference images;
distribute reusable configurations;
make content available to other users;
appear in discovery or recommendation systems; and
receive creator rewards linked to eligible use.

Fraw may assess whether these functions cause the Service, or part of the Service, to fall within a regulated category under Vietnamese law.

While that assessment is pending or where compliance measures are incomplete, Fraw may:

disable new publication;
limit publication to verified adults;
allow browsing without allowing publication;
allow private extensions only;
disable comments or messaging;
disable creator following or ranking;
restrict public sharing;
require phone verification;
apply manual review;
limit the number of published extensions; or
restrict the function in Vietnam.

No user or creator has a contractual right to require Fraw to classify the Service in a particular way.

8. Published Extensions

A Published Extension is an extension that Fraw permits an eligible creator to make available to other users through the Service.

A Published Extension may include:

a title;
a description;
prompts or instructions;
configurations;
reference images;
before-and-after examples;
generated examples;
thumbnails;
creator name;
public metadata;
content warnings;
age restrictions; and
other information selected or approved for publication.

Publication is separate from creation.

The ability to create a private extension does not create a right to publish it.

Submission for publication does not guarantee:

approval;
immediate review;
continued publication;
availability in Vietnam;
availability outside Vietnam;
recommendation;
ranking;
visibility;
user traffic;
Diamond earning; or
creator payout.

9. Requirements for Vietnam creators

Before publishing an extension or accessing another creator function, Fraw may require a creator in Vietnam to:

satisfy the applicable subscription-tier requirement;
meet the minimum age requirement;
have legal capacity;
maintain an account in good standing;
verify an email address or phone number;
complete identity or creator verification;
confirm ownership and permissions;
accept updated creator or content rules;
disclose commercial or promotional relationships;
complete tax or payment information where applicable;
pass safety, quality, fraud, and compliance review;
comply with applicable Vietnamese law; and
satisfy other eligibility conditions displayed in the Service.

Fraw may require additional verification where:

a creator publishes high-risk content;
a creator accumulates substantial activity;
a creator requests withdrawal;
reports or complaints are received;
multiple related accounts are detected;
the creator participates in a commercial campaign; or
a regulatory requirement applies.

10. Creator responsibility for published content

Creators are responsible for all content they submit, configure, publish, or make available through an extension.

A creator must ensure that the creator has all necessary:

ownership rights;
licences;
permissions;
consents;
image releases;
personality-right permissions;
privacy permissions;
intellectual-property rights;
parental or guardian permissions;
advertising authorizations;
commercial permissions; and
other lawful authority

needed to provide and publish the relevant content.

A creator must not assume that:

material found online is free to use;
an image generated by AI is automatically free from third-party rights;
having possession of a photograph gives the right to publish it;
consent to take a photograph includes consent to use it in an AI extension;
consent for private processing includes consent for public publication;
a public figure has waived image or personality rights;
use in a template is automatically fair use or otherwise permitted; or
Fraw’s approval transfers legal responsibility from the creator to Fraw.

Fraw’s review, publication, ranking, or promotion of an extension does not constitute a legal opinion or guarantee that the content is lawful.

11. Prohibited and restricted content

Creators and users must not create, publish, distribute, promote, or use extensions for content that:

violates Vietnamese law;
infringes intellectual-property rights;
violates privacy or image rights;
uses personal data without lawful authority;
impersonates another person or organization unlawfully;
fabricates official government documents or communications;
creates deceptive identity documents;
facilitates fraud, scams, phishing, or financial deception;
contains unlawful false information presented as authentic;
threatens national security, public order, or public safety;
unlawfully misrepresents governmental bodies or public authorities;
promotes violence, terrorism, or criminal conduct;
contains child sexual-abuse material;
sexually exploits or endangers children;
contains non-consensual intimate imagery;
facilitates harassment, threats, stalking, or abuse;
contains malicious code or technical exploits;
promotes prohibited goods, services, gambling, or unlawful commercial activity;
infringes advertising or consumer-protection rules;
circumvents content controls, verification, or geographic restrictions;
manipulates platform rankings, traffic, or rewards; or
otherwise violates the Terms, Creator Policy, community rules, or notices shown in the Service.

Fraw may apply stricter restrictions in Vietnam than in other markets.

12. False, harmful, or misleading information

Users and creators must not present AI-generated, altered, reconstructed, or synthetic content as authentic evidence where doing so is likely to deceive or cause harm.

Restricted conduct may include:

fabricated news images;
fake governmental announcements;
false emergency information;
manipulated political imagery;
fake public-authority statements;
fabricated evidence of crime or misconduct;
deceptive medical or financial representations;
fraudulent product claims;
misleading before-and-after results;
deceptive endorsements; and
synthetic content intended to damage another person’s reputation.

Vietnamese authorities have emphasized platform responsibility for detecting and removing harmful or false information under the online-information framework.

Fraw may require:

an AI-generated-content label;
an alteration disclosure;
a content warning;
removal of misleading metadata;
restriction of public distribution;
geographic blocking;
manual review; or
complete removal.

13. Content involving public authorities and public events

Fraw may subject content involving the following to enhanced review or restriction:

Vietnamese governmental bodies;
public officials;
law-enforcement bodies;
military organizations;
courts;
elections or political activity;
public emergencies;
natural disasters;
public-health events;
official documents;
public-security events;
breaking news;
major accidents; and
other matters of substantial public concern.

Fraw may prohibit content that:

falsely appears to originate from an authority;
falsely represents an official decision;
creates confusion about an emergency;
impersonates a public official;
fabricates evidence;
encourages unlawful action;
is likely to undermine public safety; or
otherwise creates unacceptable legal or safety risk.

This section does not mean that all artistic or fictional depictions are prohibited. Fraw may consider:

context;
labelling;
likelihood of deception;
intended audience;
public availability;
local law;
user reports; and
potential harm.

14. Personal images, face-containing images, and privacy

Creators and users must not upload, use, publish, or distribute an image of another individual unless they have the rights and lawful authority necessary for the intended processing and publication.

Special care is required where content contains:

a recognizable face;
a child;
a private individual;
intimate or sensitive material;
medical information;
precise-location information;
identity information;
financial information;
or other personal data.

Private permission to process an image does not automatically include permission to:

publish it;
make it reusable by other users;
use it for commercial promotion;
include it in a before-and-after example;
include it in an extension thumbnail;
distribute it outside its original context; or
use it after the permission has been withdrawn.

Additional information concerning Fraw’s processing of personal data and Face-Containing Images is provided in the Privacy Policy and Vietnam Privacy Addendum.

15. Children

Fraw may restrict or prohibit children or users below a specified age from:

publishing extensions;
maintaining public creator profiles;
publicly sharing content;
earning Diamonds;
requesting withdrawal;
participating in commercial campaigns;
uploading images of other children; or
using public creator features.

Where parental or guardian consent is legally required, Fraw may require:

consent from a parent or legal guardian;
verification of parental authority;
age verification;
additional account restrictions;
child-specific notices; or
other safeguards.

Fraw may remove or restrict content involving children where:

lawful authority is unclear;
publication creates privacy or safety risk;
the content sexualizes or exploits a child;
the content could facilitate identification, stalking, grooming, or abuse;
consent cannot be verified; or
removal is otherwise reasonably necessary to protect the child.

16. Public reporting tools

Fraw may provide reporting tools that allow users and third parties to report:

unlawful content;
false or misleading information;
impersonation;
intellectual-property infringement;
unauthorized use of an image;
privacy violations;
child-safety concerns;
harassment or threats;
scams or fraud;
non-consensual intimate imagery;
harmful AI-generated output;
prohibited commercial content;
manipulated public-information content; or
other violations.

A report should include, where available:

the extension or content concerned;
the creator or account concerned;
a description of the alleged violation;
the reason for the report;
relevant evidence;
contact information;
confirmation of authority where acting for another person; and
the requested resolution.

Fraw may request additional information before taking action.

17. Content-review and takedown process

After receiving a report or identifying a concern, Fraw may:

conduct automated screening;
conduct manual review;
temporarily restrict the content;
suspend new generations through an extension;
reduce visibility;
add a warning;
request information from the creator;
require changes;
disable publication in Vietnam;
disable publication globally;
archive the extension;
remove associated images;
preserve relevant records;
refer the issue to a service provider;
refer the issue to an app store;
refer the issue to a competent authority;
suspend creator functions;
suspend the account;
reverse related Diamonds; or
take another appropriate action.

Fraw may take urgent action without first contacting the creator where reasonably necessary to address:

child-safety risks;
non-consensual intimate content;
credible threats;
fraud;
malicious code;
legal orders;
emergency misinformation;
serious privacy violations; or
other significant harm.

Fraw may later restore content if a restriction is found to be unnecessary.

18. Regional blocking

Fraw may restrict an extension or other content only within Vietnam while allowing it to remain available elsewhere.

Regional blocking may include:

hiding the extension from Vietnamese users;
preventing search or discovery in Vietnam;
disabling new generations in Vietnam;
preventing Vietnamese accounts from publishing the content;
disabling associated referral or reward activity in Vietnam;
blocking access through known Vietnamese IP addresses;
applying age or verification restrictions; or
taking another reasonable geographic measure.

Regional blocking does not guarantee that every attempt to access restricted content can be prevented.

Users must not use a VPN, proxy, false location, related account, or other circumvention method to evade a lawful Vietnam restriction.

19. Repeat offenders

Fraw may treat a user or creator as a repeat offender based on:

repeated policy violations;
repeated lawful complaints;
repeated intellectual-property infringements;
repeated privacy violations;
repeated publication of removed content;
use of related accounts to evade enforcement;
repeated fraud or reward manipulation;
failure to cooperate with investigations; or
other patterns of serious or persistent non-compliance.

Fraw may take measures including:

longer review periods;
pre-publication review;
reduced publication limits;
suspension of public functions;
suspension of Diamond earning;
rejection of withdrawal requests;
removal of creator status;
device or payment restrictions;
account termination; or
preservation and disclosure of relevant records where legally permitted.

20. Commercial, sponsored, and advertising content

Creators are responsible for complying with Vietnamese advertising, consumer-protection, e-commerce, tax, business-registration, and licensing requirements.

A creator must clearly disclose where content:

is sponsored;
is paid for by a third party;
contains an affiliate relationship;
promotes a commercial product or service;
includes a material benefit;
represents a brand partnership; or
is otherwise advertising or promotional content.

Fraw may require creators to:

use a sponsorship label;
disclose the advertiser;
provide evidence of permission;
remove misleading claims;
remove prohibited products;
restrict the content to an appropriate audience;
comply with regulated-product rules;
provide licence or registration information; or
remove the content.

Fraw’s approval of a Published Extension does not mean that the creator has satisfied all advertising, licensing, tax, or commercial requirements.

21. Subscriptions, purchases, and credits

Subscriptions, top-ups, and other purchases may be made available through:

Apple App Store;
Google Play;
an authorized web-payment channel; or
another payment provider.

Before purchasing, users should review:

price;
currency;
taxes;
billing period;
automatic-renewal terms;
included credits;
expiry rules;
cancellation process;
refund rules; and
available features.

The deletion of the Fraw application or Fraw account may not automatically cancel an Apple App Store or Google Play subscription.

Users remain responsible for cancelling through the applicable store or payment provider.

Credits:

are subject to the global Terms;
do not create ownership rights;
cannot ordinarily be exchanged for cash;
do not guarantee access to higher-tier functions;
do not guarantee publication rights;
do not guarantee Diamond earning;
do not guarantee creator withdrawal; and
may be subject to expiry or adjustment rules.

22. Diamond earning in Vietnam

Fraw may enable or disable Diamond earning independently from publication.

The fact that a creator can publish an extension does not necessarily mean that activity involving that extension will generate Diamonds.

Diamond eligibility may depend on:

whether Diamond earning is enabled in Vietnam;
whether the creator remains eligible;
whether the Published Extension remains eligible;
whether the user activity is genuine;
whether eligible paid credits are used;
whether the relevant purchase has settled;
whether the activity complies with law and policy;
whether the activity passes fraud review;
whether the content remains available;
whether the activity is excluded under the Creator Policy; and
other rules displayed in the Service.

Unless Fraw expressly states otherwise, activity involving:

Free Credits;
promotional credits;
referral credits;
official extensions;
Rebuild;
Blend;
private extensions;
self-use;
related accounts;
fraudulent traffic;
refunded transactions; or
prohibited content

does not generate eligible Diamonds.

23. Creator withdrawal and payout availability

Creator withdrawal may be unavailable in Vietnam even where:

users can publish extensions;
creators can view Diamond balances; or
Diamonds are recorded internally.

Fraw may keep withdrawal disabled until Fraw confirms:

lawful availability of the payout program;
availability of a supported payout provider;
identity-verification requirements;
tax and reporting requirements;
foreign-exchange and remittance requirements;
payment-provider approval;
sanctions and financial-crime controls;
business-registration implications;
record-retention requirements; and
operational readiness.

The display or accumulation of Diamonds does not guarantee that:

withdrawal will become available;
a payout provider will accept the creator;
Fraw will support the creator’s preferred payment method;
the creator has satisfied tax obligations;
a particular conversion rate will apply;
payment will occur within a particular period; or
Diamonds constitute an immediate or unconditional cash entitlement.

24. Creator tax and business obligations

Creators are responsible for determining whether their activities create obligations concerning:

personal-income tax;
value-added tax;
business registration;
household-business registration;
invoicing;
tax identification;
accounting;
foreign-income reporting;
foreign-exchange compliance;
advertising registration;
commercial licensing; or
other governmental charges or filings.

Fraw may require:

tax information;
identification information;
declarations;
invoices;
payment-account information;
evidence of registration; or
another document

where legally required or reasonably necessary to operate the creator program.

Fraw does not provide tax, accounting, legal, licensing, or financial advice.

25. Fraud and reward manipulation

Creators and users must not manipulate creator activity or rewards through:

self-use;
related accounts;
household accounts;
coordinated accounts;
fake accounts;
automated activity;
click farms;
device farms;
payment manipulation;
refunded purchases;
fabricated referrals;
VPN or location manipulation;
account sharing;
repeated low-value activity created primarily to earn rewards;
misleading incentives;
undisclosed paid usage; or
another artificial method.

Fraw may investigate:

account relationships;
devices;
IP addresses;
phone numbers;
login patterns;
payment methods;
payout accounts;
transaction history;
generation history;
timing patterns;
refund and chargeback activity; and
other relevant indicators.

Where manipulation is suspected, Fraw may:

delay Diamond calculation;
hold Diamonds;
reverse Diamonds;
deny withdrawal;
request additional verification;
suspend publication;
suspend creator functions;
terminate accounts; or
preserve and disclose records where legally permitted.

26. Governmental and regulatory requests

Fraw may receive requests, orders, notices, or inquiries from Vietnamese:

courts;
ministries;
regulators;
cybersecurity authorities;
telecommunications or online-information authorities;
consumer-protection authorities;
personal-data protection authorities;
tax authorities;
law-enforcement bodies; and
other competent authorities.

Subject to applicable law, Fraw may:

verify a request;
seek clarification;
preserve relevant information;
restrict or remove content;
block access in Vietnam;
restrict an account;
suspend a function;
provide account or technical records;
disclose personal data;
provide regulatory information;
cooperate with an investigation;
challenge an invalid or excessive request; or
take another legally permitted action.

Fraw may be legally prohibited from informing the affected user or creator about a request, investigation, preservation instruction, disclosure, or enforcement action.

27. Data processing and privacy

Fraw processes personal data relating to Vietnam users and creators as described in:

the Privacy Policy;
the Vietnam Privacy Addendum;
this Vietnam Regional Notice;
relevant consent or product notices; and
applicable law.

Information processed in connection with regional and creator functions may include:

account information;
phone-verification status;
country or region;
creator profile information;
extension content;
publication records;
moderation history;
reports and complaints;
Diamond records;
transaction records;
withdrawal requests;
payout status;
fraud signals;
technical logs;
regulatory records; and
communications.

Fraw may process such information outside Vietnam and may prepare or maintain processing and cross-border transfer documentation as required by law.

28. Cookies, SDKs, and analytics

Fraw may use:

cookies;
local storage;
mobile SDKs;
app-instance identifiers;
device identifiers;
analytics systems;
crash-reporting tools;
diagnostic tools;
fraud-prevention technologies; and
security technologies.

Additional details are provided in the Cookie Policy or any replacement Cookies and Similar Technologies Policy.

Where required, Fraw may request consent before using optional analytics.

Fraw does not intend to send the following to analytics providers:

uploaded images;
Face-Containing Images;
generated images;
complete prompts;
private gallery content;
extension reference images;
complete payment information; or
private support communications,

unless separately disclosed and lawfully authorized.

29. App-store disclosures

Feature availability shown in Apple App Store or Google Play listings may be subject to the regional restrictions described in this Vietnam Regional Notice.

Fraw may update store listings to explain:

unavailable creator functions;
unavailable withdrawal;
age restrictions;
verification requirements;
subscription terms;
content-reporting tools;
data collection;
account deletion;
photo and camera access;
public-extension functionality; and
other material regional conditions.

Users should review the current store listing and in-app purchase screen before purchasing or relying on a feature.

Where a store listing conflicts with a mandatory legal right, the mandatory legal right will apply.

30. Changes in regional configuration

Fraw may modify the Vietnam configuration to reflect:

changes in law;
regulatory guidance;
platform classification;
phone-authentication requirements;
local-storage requirements;
local-presence requirements;
content-removal obligations;
app-store rules;
payment support;
payout support;
provider availability;
fraud risk;
moderation capacity;
technical feasibility; or
operational readiness.

Changes may include:

enabling or disabling features;
requiring verification;
adding a local contact;
limiting public publication;
disabling new purchases;
changing supported payment methods;
restricting certain models;
changing moderation rules;
disabling Diamond earning;
enabling or disabling withdrawal;
requiring additional consents; or
withdrawing the Service from Vietnam.

Fraw will provide notice where required by applicable law.

31. Suspension or withdrawal from Vietnam

Fraw may restrict, suspend, remove, or discontinue some or all of the Service in Vietnam where:

a required registration, licence, notification, filing, or approval is unavailable;
a local-presence or local-storage requirement applies and cannot reasonably be satisfied;
a competent authority directs restriction;
an app store removes or restricts the application;
an infrastructure or payment provider stops supporting Vietnam;
required verification cannot be implemented;
lawful content-removal requirements cannot be supported;
continued operation creates unacceptable legal, security, financial, or reputational risk; or
continued operation is not commercially or technically feasible.

Fraw may separately:

close new registrations;
disable new purchases;
disable publication;
disable public extensions;
disable Diamond earning;
suspend withdrawal;
remove the application from local stores;
restrict access from Vietnam; or
terminate Vietnam availability.

Where mandatory law requires a refund, notice, account-access period, data-export opportunity, or other remedy, Fraw will provide the required remedy.

32. User and creator cooperation

Users and creators must provide accurate information reasonably requested to:

confirm location;
verify an account;
comply with age requirements;
investigate a report;
assess publication rights;
investigate fraud;
process a legal request;
comply with tax or payment requirements;
respond to a regulator; or
maintain lawful operation of the Service.

Users and creators must not:

provide false verification information;
impersonate another person;
use another person’s phone number without authority;
conceal related accounts;
delete or alter evidence during an investigation;
evade a regional restriction;
republish removed content through another account; or
interfere with Fraw’s compliance procedures.

33. No guarantee of continued creator participation

Participation as a Vietnam creator does not guarantee:

continued creator eligibility;
publication approval;
continued availability of an extension;
visibility;
ranking;
recommendations;
traffic;
Diamond earning;
withdrawal;
payout;
income;
a business relationship with Fraw; or
continued availability of the creator program in Vietnam.

Creator participation does not create:

an employment relationship;
an agency relationship;
a partnership;
a joint venture;
a franchise;
a fiduciary relationship; or
authority to bind or represent Fraw.

34. Language

This Vietnam Regional Notice may be made available in English and Vietnamese.

The Vietnamese version is intended to improve accessibility, transparency, and understanding for users in Vietnam.

If there is an inconsistency between versions:

the English version will control to the extent permitted by law; and
the Vietnamese version or mandatory Vietnamese interpretation will apply to the extent required by Vietnamese law.

Any in-app notice presented only in Vietnamese remains binding to the extent it clearly applies to the relevant Vietnam function and is consistent with mandatory law.

35. Updates to this Vietnam Regional Notice

Fraw may update this Vietnam Regional Notice to reflect:

changes to the Service;
changes to Vietnam law;
regulatory guidance;
changes in platform classification;
account-authentication requirements;
content-governance requirements;
creator-program changes;
payout changes;
payment-provider changes;
app-store requirements;
security or fraud developments; or
improvements to clarity.

If Fraw makes a material change, Fraw may provide notice:

through the Service;
by email;
through the creator dashboard;
on Fraw’s website;
through an app-store update; or
by another reasonable method.

The revised Vietnam Regional Notice becomes effective on the date stated at the top.

Continued use after that date constitutes acknowledgement and acceptance of the revised notice, except where express consent or another action is legally required.

36. Contact and reporting

Questions, requests, reports, or complaints concerning this Vietnam Regional Notice may be sent to:

Untitled Labs Limited 20/F, Harbourside HQ 8 Lam Chak Street Kowloon Bay, Kowloon Hong Kong

General Support: hi@fraw.ai Suggested subject line: Vietnam Regional Service Request

For a privacy request, use:

Suggested subject line: Vietnam Privacy Request

For a report concerning a Published Extension or creator, include where possible:

extension title;
extension link or identifier;
creator name;
description of the issue;
supporting evidence;
the country in which the content was viewed;
your relationship to the affected person or rights holder; and
the requested resolution.

For urgent child-safety, non-consensual intimate-image, credible threat, fraud, or serious privacy concerns, clearly state the urgent nature of the report.

Where Fraw appoints a Vietnam-specific representative, online-information contact, cybersecurity contact, personal-data contact, grievance contact, or other responsible person, the relevant information may be published through:

this Vietnam Regional Notice;
the Vietnam Privacy Addendum;
the Privacy Policy;
Fraw’s website;
the Service;
an app-store listing;
a Vietnamese regulatory register; or
another reasonable method.

This Vietnam Regional Notice forms part of the rules governing the use of Fraw in Vietnam.