Terms of Use and Policies

Provider: CÔNG TY TNHH CÔNG NGHỆ LOHA (trading as LoHa Tech)

• Tax code: 0111509748

• Registered office: My Luong Hamlet, Tran Phu Commune, Hanoi City, Vietnam

• Telephone: 0399692275

• Email: lohatech.hr@gmail.com

• Website: https://lohapage.com

Use the contacts above for questions, complaints, or to exercise any right described in this document.

LoHa Page is a SOFTWARE TOOL that runs on your own computer. It helps you automate posting, scheduling and commenting on Facebook Pages and Instagram accounts that you lawfully administer.

The software works through the official programming interface published by Meta. We do NOT use and do NOT provide password-cracking tools, unauthorised input simulation, or any other unauthorised means of access.

We sell a TIME-LIMITED RIGHT TO USE THE SOFTWARE. We do NOT sell, rent or broker: Facebook or Instagram accounts, Pages, groups, followers, likes, engagement, comments, access tokens, or any third-party resource.

We do NOT post on your behalf. Every post and comment is carried out by software running on your machine, using access you supplied, with content and timing you configured. You create the content and you are responsible for it.

Because the software runs on your machine and content goes straight from your machine to the platform, we do NOT preview, do NOT moderate, and are in fact TECHNICALLY UNABLE to moderate what you post.

LoHa Page is an independent product. It is NOT affiliated with, sponsored by, endorsed by, or representative of Meta Platforms, Inc. or any Meta company.

You must be at least 18 years old, or otherwise have full civil act capacity under Vietnamese law, to enter into this agreement. If you are contracting for an organisation, you confirm you are duly authorised.

Each licence may be used on ONE computer. The machine is bound to your account when you first sign in inside the software.

You are responsible for keeping your username and password confidential. Anything done through your account is treated as done by you, unless you show the account was taken over through no fault of yours and you told us as soon as you noticed.

You must give accurate information when registering and keep it up to date.

When registering an account on the website or inside the software, you are asked to tick an explicit box confirming you have read and agree to this document. The box is not pre-ticked; you must tick it yourself before you can register.

We record the time you accepted and the VERSION NUMBER of this document at that moment, so that it is clear exactly which content you agreed to.

Agreeing to this document does NOT include and does NOT require you to consent to us using your information for purposes that are not necessary to perform the contract, such as marketing or promotional messages. Those purposes are asked separately, with their own tick box, and you may leave it unticked and still register normally.

You can read this document in full at any time at the address published on the website, both before and after registering.

We grant you a time-limited, non-exclusive, non-transferable and revocable right to use the software, within the scope and term of the plan you purchased.

All intellectual property rights in the software, source code, interface, documentation and brand belong to the Company. This agreement does NOT transfer ownership.

Licence details are in Part B.

You undertake to use the software in accordance with Vietnamese law, the law of the place where you operate, and the rules of the platform you post to.

You undertake to use the software ONLY on Pages and accounts you own or are lawfully authorised in writing to manage.

The full list of prohibited conduct is in Part C. Breaching Part C breaches this document.

You bear sole responsibility for the content you publish, including administrative, civil and criminal liability where applicable under Vietnamese law.

Facebook and Instagram are Meta platforms. Meta issues and changes its terms and platform policies at its own discretion, without your consent or ours.

Automating actions may not be consistent with Meta’s terms of service or platform policies as they stand at any given time. It is your responsibility to check and comply with those terms.

Meta may restrict, reduce distribution of, suspend or permanently disable a Page, account or app at any time, for any reason, without notice and without explanation. That is Meta’s right and is outside our control.

YOU ACCEPT THIS RISK WHEN YOU DECIDE TO BUY. We give no undertaking, no warranty, and accept no responsibility if your Page or account is restricted, loses reach, is suspended or is deleted.

Meta may change its programming interface or policies at any time, which may stop some features working. We will make reasonable efforts to update the software, but we do not guarantee that every feature remains available.

The software is provided “AS IS” and “AS AVAILABLE”.

To the extent permitted by law, we disclaim implied warranties of merchantability, fitness for a particular purpose, and uninterrupted or error-free operation.

We make NO promise about business results: no promise of revenue, reach, engagement, orders or advertising performance. Results depend on your content, your market and the platform’s algorithms.

This disclaimer does NOT apply to warranties that Vietnamese law makes mandatory and does not permit to be excluded.

To the extent permitted by law, we are not liable for indirect, incidental or consequential loss, including lost profit, lost business opportunity, loss of reputation, or the restriction or suspension of a Page or account on a third-party platform.

Except in the cases in the next paragraph, the total liability of CÔNG TY TNHH CÔNG NGHỆ LOHA for all claims arising from a single matter shall not exceed the AMOUNT you actually paid us in the 12 months immediately before the event giving rise to the claim.

⚠️ THE ABOVE LIMIT DOES NOT APPLY, and we remain fully liable under the law, where: (a) we cause harm intentionally; (b) the harm is to life or health; (c) we breach personal data protection rules; (d) in any other case where Vietnamese law does not permit liability to be limited or excluded.

Nothing in this document limits or excludes your right to complain, denounce or bring legal proceedings as provided by law.

You agree to indemnify CÔNG TY TNHH CÔNG NGHỆ LOHA, its managers, staff and partners against claims, demands, losses and reasonable costs (including legal fees) arising from: (a) content you publish; (b) your breach of this document; (c) your breach of law or infringement of a third party’s rights; (d) your use of the software on Pages or accounts you have no lawful right to.

This obligation does not extend to loss caused by our own fault.

Where a competent State authority makes a lawful written request, we are obliged to provide relevant information as required by law.

We may suspend or terminate your right to use the software where we reasonably believe you have: breached this document; used the software unlawfully; shared, rented or resold your licence; interfered with copy-protection mechanisms; or harmed our systems or those of a third party.

Except in cases of serious breach or where a State authority so requires, we will notify you before terminating and give you a reasonable opportunity to explain or remedy.

On termination you must stop using the software and remove it from your device. Any refund is handled under Part E.

You may stop using the software and request deletion of your account at any time.

We may amend this document when the law changes, when the product changes, or to clarify wording. Each content change updates the version number shown at the top of the page.

For changes that materially disadvantage you, we will publish them on this page at least 15 days before they take effect and notify you inside the software.

If you do not accept an amendment, you may stop using the software and request a refund of the fee corresponding to the unused portion of your current plan.

Continuing to use the software after an amendment takes effect means you accept it.

Force majeure means an event occurring objectively, which could not be foreseen and could not be overcome despite every necessary measure within the available capacity being applied, as defined in the Civil Code.

It includes, without limitation: natural disaster, epidemic, war, strike, wide-area telecommunications or power infrastructure failure, large-scale cyber attack, and decisions of a competent State authority that make performance impossible.

The affected party is not liable for failing to perform during the event, provided it notifies the other party within a reasonable time and applies remedial measures within its capacity.

Time during a force majeure event does NOT count towards the fault-remedy deadlines in section E3.

If the event continues for more than 60 consecutive days and prevents us from providing the service, you may terminate and receive a refund of the fee for the unused period.

We may suspend authentication, licensing or other online services for maintenance, upgrades or to handle information security incidents.

For planned maintenance we give reasonable advance notice and prefer low-impact hours. A short maintenance interruption is not a technical fault attributable to the software under section E3.

The software depends on third-party services (the Meta platforms, hosting infrastructure, payment services). We do not control and are not responsible for those services being interrupted, changing their terms, changing quality, changing prices, imposing quotas or shutting down.

All our guides, marketing material and support responses are informational only. They are NOT legal advice and do not replace a lawyer’s advice on your particular situation.

Nothing in this section applies where Vietnamese law does not permit liability to be limited or excluded.

We meet our own tax obligations on the fees you pay, and issue invoices as required on request (see section E1).

Revenue you generate from your own business — including revenue from Pages and accounts you operate using the software — is YOUR responsibility to declare and pay tax on under tax law.

We do not declare or pay tax on your behalf and have no obligation to determine the tax position of your business.

This document is governed by and construed under the laws of the Socialist Republic of Vietnam.

The parties will first attempt to resolve any dispute by negotiation within 30 days of a written notice of dispute.

If negotiation fails, you may choose any dispute resolution method available under Vietnamese consumer protection law, including mediation, arbitration, or proceedings before a competent People’s Court in Vietnam.

This clause does not remove your right to sue and does not require you to give up any dispute resolution method the law allows.

If any provision is held invalid, the remaining provisions stay in force.

The software is LICENSED FOR USE, not sold outright. You receive a right to use; the Company retains ownership.

The right granted is: time-limited to the plan purchased, non-exclusive, non-transferable, not sublicensable, and limited to one computer per licence.

Computer programs are protected by copyright under Law on Intellectual Property No. 50/2005/QH11 and amending Laws No. 36/2009/QH12, 42/2019/QH14 and 07/2022/QH15.

Install and use the software on one computer, for your own operations or those of the organisation that bought the licence.

Back up your own data produced by the software.

Receive updates released while your licence remains valid.

• Copy, distribute, re-upload, rent, lend or resell the software or the licence.

• Reverse engineer, disassemble or analyse machine code to discover source code or algorithms.

• Disable, circumvent or interfere with copy protection, licensing or machine-binding mechanisms.

• Remove or obscure copyright or trademark notices in the software.

• Use the software to build a competing product.

• Use the software contrary to Part C.

The software may check for and download updates to fix bugs, patch security issues or adapt to third-party platform changes.

We may adjust, replace or discontinue a feature when a third-party platform changes or when the feature no longer complies with legal requirements.

If discontinuing a feature materially changes the value of your plan, sections A12 and E3 apply.

Your content (video, images, text), your configuration and your platform access tokens are stored ON YOUR OWN COMPUTER and are not sent to our servers.

You are responsible for backing up your own data. We hold no copy and cannot restore it if your computer fails, is lost or is reinstalled.

Processing of account data is covered by Part D.

The licence takes effect when you accept this document and runs until your licence expires or is terminated.

The licence terminates immediately if you breach section B3.

On termination you must stop using and remove the software. The sections on intellectual property, indemnity and limitation of liability survive termination.

LoHa Page is a neutral tool. The same feature can run a decent shop or be misused to spread unlawful content.

We cannot moderate your content because the software runs on your machine. So the boundary has to be written down clearly, and responsibility assigned clearly, from the start.

When you breach it, you are the one who faces enforcement — under Vietnamese law, administrative and criminal liability attaches to the person who commits the act.

You must NEVER use the software to publish, distribute or comment with:

• Content propagandising against the Socialist Republic of Vietnam; inciting violence or ethnic or religious division; distorting history or denying revolutionary achievements — within the prohibited acts under Article 7 of Law on Cybersecurity No. 116/2025/QH15.

• Fabricated or false information, slander, or content offending the honour, dignity or reputation of any agency, organisation or individual.

• Forged content produced with artificial intelligence or other technology to fake another person’s image, video or voice.

• Pornographic or violent content, content harmful to children, or content contrary to public morals.

• Content impersonating another organisation or individual.

• Content infringing copyright, related rights or industrial property rights: images, video, music or trademarks you have no lawful right to use.

• Trading in prohibited goods, counterfeit or imitation goods, goods infringing intellectual property, smuggled goods, goods of unclear origin, or expired goods — within the prohibited acts under Article 6 of Law on E-commerce No. 122/2025/QH15.

• Fraud or deception in e-commerce activity.

• Running or promoting gambling, betting, loan-sharking, or unlicensed multi-level marketing.

• Advertising goods or services that are prohibited or restricted from advertising under advertising law.

• Unlawful capital raising or unlicensed investment solicitation.

• Unlawfully collecting, using, disclosing or trading another person’s personal data.

• Processing personal data for unlawful purposes.

Prohibited acts concerning personal data are set out in Article 7 of Law on Personal Data Protection No. 91/2025/QH15.

If you use the software to process your own customers’ personal data, YOU are the data controller for that data and you must independently meet your obligations under Law No. 91/2025/QH15, including obtaining valid consent from the data subjects.

• Using the software on Pages or accounts you neither own nor are lawfully authorised to manage.

• Taking over another person’s Page or account.

• Creating fake accounts or registering with forged documents.

• Using the software to attack, overload or disrupt a third party’s systems.

• Selling, renting or brokering accounts, Pages, followers or engagement.

From us: suspension or termination of your right to use, without refund, under section A11.

Under the law, depending on the nature and seriousness, conduct may attract:

• Administrative penalties in cybersecurity and personal data protection under Decree No. 330/2026/ND-CP, effective 19/8/2026.

• Administrative penalties in post, telecommunications, radio frequency, electronic transactions and information technology under Decree No. 174/2026/ND-CP, effective 01/7/2026.

• Criminal liability under Penal Code No. 100/2015/QH13 (as amended), in which Articles 285 to 294 set out offences in information technology and telecommunications networks.

Legal responsibility for content and conduct rests with YOU, as the person who decides the content and instructs the software to act.

If you believe a LoHa Page user is breaching this part or infringing your rights, send a notice to lohatech.hr@gmail.com describing the conduct with evidence.

We will receive it, verify it as far as we technically can, and act on the offending account under section A11.

Note: we have no power and no ability to remove content already published on Facebook or Instagram. Removing platform content is for Meta or the account holder.

Data controller: CÔNG TY TNHH CÔNG NGHỆ LOHA, tax code 0111509748, registered office My Luong Hamlet, Tran Phu Commune, Hanoi City, Vietnam.

Send any personal data request to: lohatech.hr@gmail.com.

⚠️ Important point about roles: for YOUR ACCOUNT data, we are the data controller. But for the personal data of YOUR OWN CUSTOMERS that you process using the software, YOU are the controller and you are responsible for complying with Law No. 91/2025/QH15.

When you create an account: username, password (stored as a one-way hash that we cannot read), email address, and phone number if you provide one.

When you sign in inside the software: machine identifier, machine name, operating system, software version, IP address.

When you buy a plan: order number, amount, plan name, billing cycle, and transaction reconciliation data returned by the bank.

When you accept this document: the time of acceptance and the document version number — to evidence what you agreed to.

Activity logs: sign-in, activation and order timestamps — used for technical support and fraud prevention.

All of the above is basic personal data. We do NOT deliberately collect sensitive personal data.

We do NOT collect your Facebook or Instagram password. The software neither asks for nor stores platform passwords.

We do NOT send your access tokens to our servers. Tokens are encrypted using the operating system’s protection mechanism and stay on your computer.

We do NOT collect your posts, images or videos. All content stays in a folder on your machine and goes directly from your machine to the platform.

We do NOT store bank card numbers. You pay directly through your own banking app.

Group 1 — processing to PERFORM THE CONTRACT with you. This group is technically necessary to provide the software, and the ground is contract performance, NOT separate consent:

• Authenticating your account and checking licence validity.

• Processing orders and activating plans.

• Technical support, complaint handling and transaction reconciliation.

• Enforcing one-licence-one-machine to prevent licence sharing, and detecting fraud.

Group 2 — processing based on YOUR SEPARATE CONSENT. This group is OPTIONAL; you may refuse and still use the software normally:

• Sending information about new features, promotions and special offers.

We ask for Group 2 consent separately, with its own box that is never pre-ticked, kept apart from the box accepting these terms. You may withdraw it at any time.

We do NOT use your data for targeted advertising and we do NOT sell data.

Under Article 9 of Law No. 91/2025/QH15, a data subject’s consent is valid only where it is voluntary and the subject clearly knows: the type of personal data processed, the purpose of processing, the data controller, and the data subject’s rights and obligations. This document is published so that you know those things before consenting.

Silence or lack of response is not consent. Tick boxes are never pre-ticked.

Under Article 10 of Law No. 91/2025/QH15, you may withdraw consent and request restriction of processing at any time. Withdrawal does not affect the lawfulness of processing carried out beforehand.

Note: withdrawing Group 2 consent does not affect your use of the software. But if you ask us to delete Group 1 data, we lose the technical basis to validate your licence and the contract ends.

Under Article 8 of Law on Personal Data Protection No. 91/2025/QH15, you have the right to:

• Know how your personal data is processed.

• Consent or refuse consent to processing of your personal data.

• Access, view, correct or request correction of your personal data.

• Request provision of your personal data.

• Request erasure of your personal data.

• Withdraw consent and request restriction of processing (Article 10).

• Object to processing of your personal data.

• Complain, denounce, sue and claim compensation as provided by law.

To exercise these rights, email lohatech.hr@gmail.com with enough information to verify your identity. We respond within the period required by law, and within 72 hours for ordinary requests.

Supabase — database hosting and account authentication.

Beneficiary banks and payment reconciliation providers — processing and reconciling bank transfers.

Cloudflare — website and download infrastructure, and aggregate traffic measurement (page views, pages viewed, country, device type). This tool sets NO cookies and does not track you across other websites.

We do NOT sell, trade or rent your personal data to anyone for advertising purposes.

We may provide data to a competent State authority on a lawful written request.

⚠️ Some infrastructure providers listed in D7 have servers outside Vietnam. Your account data may therefore be stored or processed abroad.

Law No. 91/2025/QH15 and Decree No. 356/2025/ND-CP set conditions and procedures for transferring personal data abroad. We undertake to meet those obligations.

We minimise what leaves the country through data minimisation: your platform tokens and post content never leave your computer.

If you do not agree to your account data being processed on infrastructure located abroad, please do not create an account and contact us before purchasing.

Account data is kept while the account remains active.

Acceptance records are kept for the life of the contract and for at least 12 months after it ends, as evidence in the event of a dispute.

Activity logs and transaction data are kept for at least 12 months for reconciliation, complaint handling and accounting and tax obligations.

After you request account deletion we erase your personal data, except what we are legally required to retain.

All connections between the software, the website and our servers are encrypted with HTTPS.

Passwords are stored as one-way hashes and cannot be reversed.

Platform tokens on your machine are encrypted using the operating system’s protection mechanism.

Internal access to data is limited on a need-to-know basis.

The website stores your session in browser storage so you need not sign in repeatedly; you can clear it with Sign out. The website uses no tracking cookies and runs no third-party advertising code.

No system is perfectly secure. Use a strong password and do not reuse it on other services.

The software is a business tool and is not directed at people under 18. We do not knowingly collect children’s personal data.

If we find we have collected a child’s data without valid consent as required by law, we will delete it.

If an incident exposes or loses personal data, we will notify the competent State authority and you, following the procedure and deadlines in Law No. 91/2025/QH15 and Decree No. 356/2025/ND-CP.

The notice will state the categories of data affected, the cause, the likely consequences and the remedial measures taken.

The price of each plan and billing cycle is published on the website before you order. The displayed price is the final amount payable.

We issue invoices as required by law on invoices and accounting records on request. Please provide invoicing details at payment or within 07 days of payment.

Payment is by bank transfer. You act directly in your own banking app; we do not store card numbers.

We encourage you to try the demo on the home page and download the installer to check it runs on your computer BEFORE paying.

Because the product can be tested before purchase, we apply the limited refund policy below.

Vietnamese law does not currently provide an automatic right to cancel a delivered digital product within a set number of days. The refund cases below are our voluntary policy, in addition to the rights the law already gives you.

Duplicate transfer, or you transferred more than the order value — we refund the FULL excess or difference as soon as reconciliation is complete.

The software is UNUSABLE FROM THE START due to a technical fault attributable to us, you reported it to support, and we could not fix it within 07 working days of receiving the report — full refund of the amount paid.

A technical fault attributable to us arises DURING USE and makes the software unusable, and we cannot fix it within 15 working days of receiving the report — refund of the fee for the unused period.

A feature does not match the description we published before your purchase, and we cannot fix it within 15 working days — refund of the fee for the unused period; full refund if you submit the claim within 30 days of payment.

We provisioned the wrong plan — we correct the provisioning, or refund the difference, as soon as it is verified.

We terminate the service unilaterally through no fault of yours — refund of the fee for the unused period.

We change the terms to your material disadvantage and you do not accept — refund of the fee for the unused period, under section A12.

A force majeure event continues for more than 60 consecutive days and prevents us from providing the service — refund of the fee for the unused period, under section A13.

⏱️ CLAIM DEADLINE: for a fault present from the start, submit within 30 days of payment. For a fault arising during use, submit while your licence is still valid. Time during a force majeure event does not count towards the fix deadlines above.

⚠️ These deadlines are conditions of the voluntary refund policy in this section. They do NOT limit the statutory limitation period for bringing proceedings, nor your statutory right to claim compensation.

You changed your mind, no longer need it, or bought the wrong thing without reading the description.

Meta restricts, suspends or deletes your Page or account for any reason. This risk is flagged in section A7.

You did not achieve the business results you hoped for.

Your computer does not meet requirements, your connection is unstable, or other software on your machine conflicts.

Meta changes its programming interface or policies and some features stop working.

Your account is terminated for breach of this document.

⚠️ None of the above removes your right to claim compensation under the law where loss arises from our fault, and none of it restricts your right to complain or bring proceedings.

If you bought the wrong plan, contact us within 24 hours of payment and before substantial use. We will prioritise switching you to the right plan and settling the difference.

Upgrades are always credited with the value of the remaining days on your current plan.

Send a request through support on Zalo or Telegram, or email lohatech.hr@gmail.com, with: your username, order number, transfer date and reason.

We respond within 03 working days.

If approved, funds are returned to the same bank account used for payment within 07 working days.

Any transfer fee is borne by the party requesting the refund, except where the fault is ours.

If you disagree with our decision, you may choose any dispute resolution method under section A16. We impose no condition restricting that right.

This document is based on the following instruments. Their status was verified on 13/09/2026:

• Civil Code No. 91/2015/QH13.

• Penal Code No. 100/2015/QH13, as amended (most recently by Law No. 86/2025/QH15) — Articles 285 to 294 on offences in information technology and telecommunications networks.

• Law on Intellectual Property No. 50/2005/QH11 and amending Laws No. 36/2009/QH12, 42/2019/QH14, 07/2022/QH15.

• Law on Protection of Consumer Rights No. 19/2023/QH15, effective 01/7/2024 — Article 25 on clauses that may not be included in consumer contracts.

• Law on Personal Data Protection No. 91/2025/QH15, passed by the 15th National Assembly on 26/6/2025, effective 01/01/2026 — Article 7 (prohibited acts), Article 8 (rights of data subjects), Article 9 (consent), Article 10 (withdrawal of consent, restriction of processing).

• Decree No. 356/2025/ND-CP of 31/12/2025 detailing the Law on Personal Data Protection, effective 01/01/2026. This Decree REPLACES Decree No. 13/2023/ND-CP.

• Law on Cybersecurity No. 116/2025/QH15, effective 01/7/2026 — Article 7 (prohibited acts). It replaces Law on Cybersecurity No. 24/2018/QH14 and Law on Network Information Security No. 86/2015/QH13.

• Law on E-commerce No. 122/2025/QH15, effective 01/7/2026 — Article 6 (prohibited acts), Article 40 (entry into force).

• Decree No. 147/2024/ND-CP of 09/11/2024 on management, provision and use of internet services and online information, effective 25/12/2024.

• Decree No. 330/2026/ND-CP on administrative penalties in cybersecurity and personal data protection, effective 19/8/2026.

• Decree No. 174/2026/ND-CP on administrative penalties in post, telecommunications, radio frequency, electronic transactions and information technology, effective 01/7/2026.

Earlier versions of this document cited Decree No. 13/2023/ND-CP, Law on Cybersecurity No. 24/2018/QH14 and Decree No. 15/2020/ND-CP. Those instruments have been replaced.

This version reflects the instruments now in force, listed in F1.

This document is published to make both parties’ rights and obligations transparent. It is not a substitute for legal advice on your particular situation.

If you need a legal assessment of your own business activity, consult a lawyer.