IT-Communications Vietnam Company Limited (hereinafter referred to as “IT-COM VIETNAM”) is a Company established under Vietnamese law. We, including IT-COM VIETNAM and Related Persons and Affiliates of IT-COM VIETNAM according to the law (hereinafter collectively referred to as "We"), understand the importance of data customer's personal. We respect your personal data and commit to protecting and processing your personal data appropriately in compliance with Vietnamese law.
This personal data processing and protection policy (“Policy”) is designed to provide customers with the most general information about personal data processing activities at IT-COM VIETNAM, includes the following basic contents:
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SECTION 1:  GENERAL RULES
SECTION 2: CONTENT PROCESSING AND PROTECTION OF PERSONAL DATA
SECTION 3: PERSONAL DATA RETENTION PERIOD
SECTION 4: RIGHTS AND OBLIGATIONS OF DATA SUBJECTS
SECTION 5: OTHER REGULATIONS


SECTION 1:  GENERAL RULES

Article 1. Subjects of application
This Policy applies to all Customers who provide their personal data to IT-COM VIETNAM through the means of providing personal data specified in this Policy.
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Article 2. Terminology used in the policy
“Personal data” means digital data or information in other forms that identifies or helps identify a specific individual, including: basic personal data and sensitive personal data. Personal data that has been de-identified no longer constitutes personal data. Personal data as defined in this Policy includes basic personal data and sensitive personal data specified in Article 3 of this Policy.
“Information that helps identify a specific person” is information formed from an individual's activities that, when combined with other data and stored information, can identify a specific person.
“Data subject” is the individual to whom the personal data reflects. When you provide your personal data to IT-COM VIETNAM, you are considered a data subject.
“Personal data processing” means any activity that affects personal data, including one or more of the following activities: collection, analysis, aggregation, encryption, decryption, modification, deletion, destruction, de-identification, provision, disclosure, transfer of personal data, and other activities that affect personal data.
Regulations on personal data protection” mean all applicable laws and regulations currently in force governing the protection of personal data, including but not limited to the Law on Personal Data Protection No. 91/2025/QH15.
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Article 3. Data collected by IT-COM VIETNAM
IT-COM VIETNAM commits to only collecting and processing personal data that has been agreed to be provided by the data subject, including part or all of the following personal data:
Basic personal data, including:
Surname, middle name, birth name, other names (if any);
Date of birth; date, month, year of death or disappearance;
Gender;
Place of birth, place of birth registration, permanent residence, temporary residence, current residence, hometown, contact address;
Nationality;
Images of individuals;
Phone number, ID card number, personal identification number, passport number, driver's license number, license plate number, personal tax code number, social insurance number, medical insurance card number economic;
Marital status
Information about family relationships (parents, children);
Information about individual digital accounts; Personal data reflecting activities and history of activities in cyberspace;
Other information associated with a specific individual or that helps identify a specific individual, which does not fall within the category of Sensitive Personal Data.
Sensitive personal data, including:
Data revealing racial origin or ethnic origin;
Political opinions; religious or belief-related views;
Information relating to private life, personal secrets, or family secrets;
Health status information;
Biometric data and genetic characteristics;
Data revealing an individual’s sexual life or sexual orientation;
Data on crimes or legal violations collected and stored by law enforcement authorities;
An individual’s location as determined through location-based services;
Login names and passwords for accessing an individual’s electronic identification account; images of identity cards, citizen identity cards, or personal identification certificates;
Usernames and passwords for bank accounts; bank card information; data on bank account transaction history; financial and credit information and other information relating to customers’ financial, securities, and insurance activities and transaction histories held by credit institutions, foreign bank branches, payment intermediary service providers, securities companies, insurance companies, and other authorized organizations;
Data tracking behavior and activities related to the use of telecommunications services, social networks, online media services, and other services in cyberspace;
Other personal data that, under the law, is required to be kept confidential or subject to stringent security measures.
 

SECTION2:  CONTENTS OF PROCESSING AND PROTECTION OF PERSONAL DATA

Article 4. Purpose of processing personal data
IT-COM VIETNAM only uses personal data provided for the purposes below or other lawful purposes as agreed between the data subject and IT-COM VIETNAM arising from time to time or other purposes. which the law stipulates.
To conduct communication and provide and exchange information about the services that IT-COM VIETNAM legally provides in accordance with the law (“Services”);
To establish technical and technological measures to simplify the entry of necessary information when data subjects register for the Service;
To confirm that the data subject has registered for the Service;
To survey and analyze the Service usage situation and the level of satisfaction with the Service of data subjects;
To implement measures to improve current Services or to develop new Services;
To send instructions or notifications about current Services or new Services to data subjects;
To invite data subjects to participate in events organized by IT-COM VIETNAM;
To send advertisements of IT-COM VIETNAM and/or Third Parties for whom IT-COM VIETNAM is obligated to advertise;
To resolve problems in the process of providing Services to data subjects;
To serve the management and operation of IT-COM VIETNAM’s business activities;
To draft agreements, contracts or other documents concluded with data subjects;
To carry out the rights and obligations of IT-COM VIETNAM arising from contracts and agreements between IT-COM VIETNAM and the data subject;
To transfer to a Third Party that has been consented to by the data subject before the transfer;
To store according to legal regulations.
 

Article 5. How to process data
IT-COM VIETNAM will securely process the data subject's personal data through the following methods:
IT-COM VIETNAM collects data through the following means:
 (i) information and documents provided by the Data Subject to IT-COM VIETNAM by filling in the requested information on the Website, sending faxes, emails, messages, documents, postal mail, direct exchanges, telephone calls, or other communication channels such as Zalo, Viber, WhatsApp, Facebook, TikTok, etc.;
 (ii) the Data Subject’s interactions on the Website; and
 (iii) agreements and contracts between the Data Subject and IT-COM VIETNAM;
IT-COM VIETNAM stores and processes personal data of data subjects through paper document processing, using office application software such as Microsoft Word, Excel, PowerPoint, OneNote, Outlook provided. by a reputable provider, storing data in a server in an environment that normal users cannot access, or storage devices such as USB sticks or hard drives.
Upon completion of data processing or when required by law or requested by the data subject, IT-COM VIETNAM will destroy and delete the data subject's personal data through methods such as using a computer. shred paper, irreversibly erase data on software, servers, storage devices, or authorize a third party to provide data destruction services.
 

Article 6: Security, processing and protection of personal data

​All personal data provided by the Customer will be absolutely confidential by IT-COM VIETNAM and stored in a server in an environment that is inaccessible to normal users and IT-COM VIETNAM professional managers. Nam will manage and use this personal data. Information will be strictly managed and there will be no cases of unauthorized access to personal information, loss, leakage or falsification of information.
IT-COM VIETNAM will only process personal data for the purposes agreed to by the data subject, and implement appropriate monitoring and protection measures to protect personal data from violations. Violating the Regulations on Personal Data Protection and preventing, combating and limiting loss or damage caused by incidents or violations.
Unless otherwise prescribed by law or prior consent of the data subject has been received, IT-COM VIETNAM commits not to provide the data subject's personal data to any Third Party. other than the Third Party specified in Article 7.2 of this Policy. In case of providing personal data to a Third Party, IT-COM VIETNAM will endeavor to impose necessary measures on this Third Party to protect personal data.
For sensitive personal data, IT-COM VIETNAM will designate a department or person in charge of protecting personal data and exchange information about this department or person in charge with the Ministry of Public Security according to regulations of  the Law on Personal Data Protection No. 91/2025/QH15.
 

Article 7: Providing personal data to third parties

​IT-COM VIETNAM has the right to provide personal data of data subjects to third parties that process personal data for the data processing purposes mentioned in Article 4 of the Policy.
“Third party” includes authorized representatives of IT-COM VIETNAM; Relevant organizations and individuals for the purpose of checking and referencing history, work experience, education level, skills, checking and identifying conflicts of interest and conflicts of interest; Contractors and service providers that IT-COM VIETNAM hires or supplements to carry out activities related to IT-COM VIETNAM business field or to fulfill IT-COM VIETNAM legal obligations IT-COM VIETNAM; Third Parties related to contracts, agreements, and commitments that the data subject enters into with IT-COM VIETNAM; Competent state agencies; Other individuals and organizations permitted by law or authorized by the data subject.
 

Article 8. Unintended consequences and damage are likely to occur during data processing
IT-COM VIETNAM has implemented appropriate security measures to prevent data subject data from being lost, used or accessed in an unauthorized manner, modified or unlawfully disclosed. However, the data subject is advised that during the process of IT-COM VIETNAM processing the data subject's personal data, the data subject's data may be lost due to unauthorized access outside IT-COM VIETNAM control ability (such as data being hacked from computer systems or servers), and data subject's data may be destroyed due to force majeure events. However, IT-COM VIETNAM will take all necessary and reasonable actions in an effort to prevent such damage from occurring during the processing of the data subject's data.


SECTION3:  PERSONAL DATA RETENTION RERIOD

Article 9: Start and end time of data processing

​Time to start data processing: IT-COM VIETNAM begins processing personal data from the time the data subject provides personal data to IT-COM VIETNAM.
End of data processing: Unless otherwise required by law, IT-COM VIETNAM       will end the processing of the data subject's personal data when (i) the purposes of the processing are completed data stated in the Policy, and (ii) there is a request from a State agency or a request from a data subject.


SECTION4:  RIGHTS AND OBLIGATIONS OF DATA SUBJECTS

Article 10: Data subject's consent
IT-COM VIETNAM only collects and processes personal data of data subjects after satisfying the following conditions:
The consent of the data subject has been obtained by clicking on the checkbox set up below the information fields that Customers are required to provide on the Website.
The data subject has received notice of personal data processing from IT-COM VIETNAM before IT-COM VIETNAM processes personal data by clicking to agree in the checkbox set below the terms. information fields that Customers are required to provide on the Website.
In addition, IT-COM VIETNAM collects consent and provides notification of the purposes of data processing during consultation calls or through other communication channels of the Company, such as Zalo, Viber, WhatsApp, Facebook, TikTok, etc..
Notwithstanding the provisions of this Article, IT-COM VIETNAM is entitled to process personal data without the consent of the data subject in the following cases:
“For the purpose of protecting the life, health, honor, dignity, rights, and lawful interests of the personal data subject or others in emergency situations; and for the purpose of protecting one’s own legitimate rights or interests, those of others, or the interests of the State or agencies/organizations, as necessary against acts infringing upon such interests;
For the purpose of addressing emergency situations; responding to threats to national security that have not yet risen to the level of a declared state of emergency; and preventing and combating riots, terrorism, crime, and legal violations; 
“For the purpose of serving the operations of state authorities and state management activities in accordance with the law;
For the purpose of performing agreements between the personal data subject and relevant agencies, organizations, or individuals in accordance with the law.
Data subjects provide personal data by the following means, and IT-COM VIETNAM collects personal data of data subjects through these means:
Fill in the requested information on the Website;
Providing information and documents via fax, email, text message, post, direct exchange or other means;
Carry out interactions on the Website;
To conduct consultation calls or use other communication means, such as Zalo, Viber, WhatsApp, Facebook, TikTok, etc.;
Agreement and contract between data subject and IT-COM VIETNAM.
 

Article 11: Rights and obligations of data subjects
In accordance with personal data protection regulations, the Data Subject has rights related to the processing of his/her personal data, including but not limited to: the right to be informed; the right to give or withhold consent; the right to request the withdrawal of consent for the processing of personal data; the right to access, rectify, or request rectification; the right to request the provision, erasure, or restriction of the processing of personal data; the right to object to the processing of personal data; the right to lodge complaints, denunciations, initiate legal proceedings, and claim compensation for damages in accordance with the law; and the right to request competent authorities or relevant agencies, organizations, or individuals involved in the processing of personal data to implement measures and solutions to protect his/her personal data in accordance with the law.

When receiving legal requests related to the exercise of data subjects' rights, IT-COM VIETNAM will handle these requests in accordance with the order, procedures, and deadlines according to the Data Protection Regulations. personal data. However, the data subject should note that exercising the data subject's rights may hinder the provision and updating of IT-COM VIETNAM products and services to the data subject.
Data subjects have obligations such as protecting their personal data; Respect and protect the personal data of others; Provide complete and accurate personal data when agreeing to process personal data; and other obligations under the Personal Data Protection Regulations.


SECTION5:  Other Provisions

Article 12: Impact assessment and transfer of personal data abroad
Assess the impact of processing personal data
IT-COM VIETNAM shall prepare a personal data processing impact assessment dossier in accordance with the template prescribed under the Law on Personal Data Protection No. 91/2025/QH15.
In case there is a change in the content of the personal data processing impact assessment file, IT-COM VIETNAM will update or supplement and send it to the Ministry of Public Security according to the Law on Personal Data Protection No. 91/2025/QH15.
Transfer of personal data abroad
Personal data is only transferred to companies belonging to the Company's group, or relevant partners abroad for purposes that have been notified in advance to the data subject.
The transfer of personal data abroad will be carried out in accordance with the personal data protection rules under the Law on Personal Data Protection No. 91/2025/QH15.
IT-COM VIETNAM will endeavor to impose necessary measures to ensure that personal data is used by the organization receiving personal data transfer abroad for the right purpose as notified to the data subject. and have safeguards against leakage to the outside.
 

Article 13: Methods and tools for editing personal data
The Data Subject may review and correct the information he/she has provided to IT-COM VIETNAM at any time, or directly contact IT-COM VIETNAM to request corrections using the contact details specified in Article 15.1 of this Policy.

Article 14: Use of “Cookies”
Customers can set whether or not to allow the use of Cookies. In many Web browsers, the use of Cookies is automatically permitted, but browser settings can also be changed to prevent the use of Cookies.
Once you have blocked the use of Cookies, you may not be able to use this Website normally, or display advertising settings that require the use of Cookies;
IT-COM VIETNAM receives your Cookie information, information about advertisements and websites you have viewed, or the environment you use, etc. from your browser automatically and then copy it to the server to use that information to improve the convenience of automatically entering your email address when logging in. This website ensures security for you. maintaining and protecting sessions, in addition to considering new services, and improving services or advertising content that is more suitable for customers.
 

Article 15: Contact information and policy updates and changes
If you have any questions about this Policy, please contact us at the following address:

IT-COMMUNIACTIONS VIETNAMCO.,LTD
Head office: 10F & 11F Thuy Loi 4 office Bldg., 102 Nguyen Xi, Binh Thanh Ward, HCMC, Vietnam

Tel: +028 6291 3321 

This Policy was issued and takes effect from July 1, 2023, amended and supplemented on January 10, 2026, and shall take effect from January 10, 2026.

We may amend and update this Policy from time to time. The revised and supplemented Policy will take effect from the time it is posted on our Website. Please visit the Website to refer to the current Policy.

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