This Privacy Policy (this “Policy”) sets out the basis upon which we may collect, use, disclose or otherwise process Personal Data (as defined below) received from individuals, as well as our practices concerning such data. In this Policy, the terms “AJIS”, “we”, “us” and “our” refer to AJIS（Vietnam）Co.,Ltd.

As we are based in Vietnam, we process your Personal Data in compliance with applicable rotection laws of Vietnam, including Decree No. 13/2023/ND-CP dated 17 April 2023 on personal data protection (“Decree 13”) and other applicable laws.

This Policy applies to Personal Data in our possession or under our control, including Personal Data in the possession of organisations which we have engaged to collect, use, disclose or process Personal Data for our purposes.

 

1. ABOUT US

Our services are made available by AJIS. AJIS is a company incorporated under the laws of Vietnam with its registered office at 4th Floor, Thien Son Office Building, 5 Nguyen Gia Thieu street, Vo Thi Sau Ward, District 3, Ho Chi Minh City, Viet Nam. AJIS is a part of AJIS Group, whose headquarters are in Chiba, Japan.

 

2. WHAT IS PERSONAL DATA?

2.1 As used in this Policy, “Personal Data” means information in the forms of signs, letters, numbers, pictures, audio, or any similar form in a digital environment that relates to the identification of a natural person or when combined with other data can be used to identify a natural person.

2.2 Depending on the nature of your interaction with us, examples of Personal Data which we may collect from you include, without limitation, your name and contact details (e.g. mailing address, e-mail address and telephone number).

2.3 Your sensitive personal data includes details about your political and religious opinions, health condition and health records, race, ethnics, genetic records, biometric and biological records, sexual behaviour, criminal records, financial and credit records, personal location or any other data which, when being infringed, will directly affect the data subject’s legal rights and interests (“Sensitive Personal Data”), as prescribed by Decree 13. Generally, we do not collect Sensitive Personal Data about you. In limited circumstances, we may collect information about your criminal convictions and offences. This happens where we are required to do so for legal or regulatory purposes or where you have provided us with such Sensitive Personal Data where it is necessary for a specific service we are providing.

2.4 We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data via email at the contact details provided in the “How to Contact Us” section below.

 

3. HOW WE COLLECT AND RECEIVE PERSONAL DATA

3.1 We generally do not collect your Personal Data unless:

(a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your Personal Data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the Purposes (as defined below) for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your Personal Data for those Purposes, or

(b) collection and use of Personal Data without consent is permitted or required by the applicable laws and regulations.

3.2 Methods of collection of Personal Data include the case where you call or otherwise contact us with enquiries, complete forms online or by hand, subscribe to receive our marketing communications or provide feedback to us. From time to time, we will receive Personal Data about you from third parties. For job applicants, such third parties may include your job placement agent. We may also automatically collect certain technical information about your equipment, browsing actions and patterns.

3.3 We shall seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorised by law).

 

4. PURPOSES FOR COLLECTION, USE & DISCLOSURE OF PERSONAL DATA

4.1 We may collect and use the Personal Data for the following purposes and any other incidental business purposes related or associated with the below (collectively, the “Purposes”):

(a) verifying your identity and age;
(b) recording your preferences and interests;
(c) managing your relationship with us;
(d) performing obligations in the course of or in connection with our provision of the products and/or services requested by you;
(e) processing payment or credit transactions;
(f) responding to, handling, and processing your enquiries;
(g) responding to, handling, and processing feedback and keeping you updated on our services;
(h) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(i) enforcing obligations owed to us;
(j) carrying out research, planning and statistical analysis;
(k) recording your visits to our premises and events;
(l) administrative purposes, such as accounting, risk management, record keeping;
(m) staff training;
(n) providing you with press releases;
(o) sending you e-mail alerts to which you have subscribed;
(p) processing your employment application;
(q) communications and procedures related to recruitment and selection, and personnel administration;
(r) contacts and/or procedures for retired employees;
(s) for other purposes that we notify you of, or will be clear from the context, at the point the Personal Data is first collected; and
(t) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Vietnam or abroad, for the aforementioned purposes.

4.2 We may use Personal Data to contact you for the above Purposes via post, fax, e-mail, SMS, telephone or any other means.

4.3 We may disclose your Personal Data where such disclosure is required in the course of the business or to third parties who provide services to us or whom we work with to perform any of the Purposes, including:

(a) our related entities, such as other entities within the AJIS Group;
(b) our business partners; and
(c) suppliers, service providers and data processors providing services to us.

4.4 We may also disclose your Personal Data to third parties where required or permitted by law.

4.5 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

 

5. PROTECTION OF PERSONAL DATA

5.1 To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

5.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

 

6. TRANSFERS OF PERSONAL DATA OUTSIDE OF VIETNAM

6.1 As we are a part of AJIS Group, your Personal Data may be transferred to one or more AJIS group companies as needed for data processing and storage, providing you with access to our services, providing customer support, making decisions about improvements to our services, content development or for other Purposes set forth in this Policy.

6.2 When you submit Personal Data to us, whether through your interactions with our website, our offices or our events, you acknowledge that your Personal Data may be transferred outside Vietnam where it will be stored and processed by us, any of AJIS group companies and our suppliers for the Purposes set out in this Policy and give your consent for such transfer to be made.

6.3 When we transfer your Personal Data outside Vietnam, we will take steps to ensure that your Personal Data continues to receive an adequate standard of protection.

 

7. RETENTION PERIOD

7.1 We may retain your Personal Data for as long as it is necessary to fulfil the Purposes for which they were collected, or as required or permitted by applicable laws. We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the Purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.

7.2 The retention period will vary depending on the Purposes for which the Personal Data was collected.

 

8. YOUR PERSONAL DATA RIGHTS

You have the following rights in relation to the Personal Data we hold about you. If you wish to make a request to exercise your rights, you can contact us by using our contact details in the “How to Contact Us” section below.

8.1 Right to Withdraw Consent: When we process your Personal Data based on your consent, you have the right to withdraw consent at any time.

8.2 Right to Access Personal Data: You have a right to obtain confirmation of whether we are processing your Personal Data, access to your Personal Data and information regarding how your Personal Data is being used by us.

8.3 Right of Data Portability: You can request to receive a copy of your Personal Data in a commonly used electronic format. This right only applies to your Personal Data that you have provided to us. The right of data portability only applies if the processing is based on your consent or if the Personal Data must be processed for the performance of a contract.

8.4 Right to Object to Processing of Personal Data: You have a right to object to processing being carried out by us if (a) we are processing your Personal Data based on legitimate interests or for the performance of a task in the public interest, (b) if we are using your Personal Data for direct marketing purposes, or (c) if Personal Data is processed for scientific or historical research or statistical purposes.

8.5 Right to Have Personal Data Erased: You have a right to request that certain Personal Data held by us is erased. This is not a blanket right to require all Personal Data to be deleted. We will consider each request carefully in accordance with the requirements of the applicable laws and regulations.

8.6 Right to Restrict Processing of Personal Data: You have a right to block the processing of your Personal Data. This right arises if you are disputing the accuracy of your Personal Data, if you have raised an objection to processing, if processing of your Personal Data is unlawful and you oppose erasure and request restriction instead, if your Personal Data is no longer required by us but you require the Personal Data to be retained to establish, exercise or defend a legal claim or if we require your Personal Data in assessing your request to object processing of Personal Data.

8.7 Right to Have Inaccurate Personal Data Rectified: You have a right to have any inaccurate or incomplete Personal Data rectified.

8.8 Right to File a Complaint: You have the right to file a complaint in the case where, in your view, we or our employees or contractors violates or fails to comply with Decree 13 or any other data protection laws.

 

9. CHANGES TO THIS POLICY

9.1 This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.

9.2 We may make changes to this Policy from time to time without any prior notice to reflect any changes to our collection, use and disclosure of your Personal Data. We may also make changes as required to comply with changes in applicable laws or regulatory requirements. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. We encourage you to review this Policy periodically to be informed of how we collect, use and disclose your Personal Data.

9.3 The latest version of this Policy in force at any given time will apply to our collection, use and disclosure of Personal Data. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

 

10. HOW TO CONTACT US

If you have any questions about this Policy or want to exercise your rights set out in this Policy, please send us an email at:

This Policy is effective December 1,2023 and supersedes all previous privacy policies issued by us.