NAVER Vietnam

Privacy Policy Contents

Article 1

Interpretation of Terms

• 1. Personal Data: Information in the form of symbols, letters, numbers, images, sounds, or similar forms in the electronic environment that is associated with a specific person or helps identify a specific person. Personal data includes basic personal data and sensitive personal data.
• • Basic personal data includes: Surname, middle name, and birth name, other names (if any); date, month, year 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; personal image; phone number, citizen identity card number, identity card number, personal identification number, passport number, driver's license number; marital status; information about family relationships (parents, children); information about an individual's digital account; personal data reflecting activities and activity history on cyberspace; other information associated with a specific person or helping identify a specific person.
• • Sensitive personal data: Personal data associated with an individual's privacy which, if violated, will directly affect the individual's legal rights and interests, including: Political views, religious views; health status and private life recorded in medical records, excluding information about blood group; information related to racial origin or ethnic origin; information about inherited or acquired genetic characteristics; information about physical attributes and biological characteristics of an individual; information about an individual's sexual life and sexual orientation; data on crimes and criminal acts collected and stored by law enforcement agencies; customer information of credit institutions, foreign bank branches, payment intermediary service providers, and other permitted organizations, including: customer identification information, account information, deposit information, deposited asset information, transaction information, information about organizations and individuals that are securing parties at credit institutions, bank branches, or payment intermediary service providers; data on an individual's location determined through positioning services; other personal data prescribed by law as specific and requiring necessary security measures.
• 2. Information helping identify a specific person: Information formed from an individual's activities which, when combined with other stored data and information, can identify a specific person.
• 3. Personal data protection: Activities of preventing, detecting, stopping, and handling violations related to personal data in accordance with the law.
• 4. Data subject: An individual reflected by personal data. In this policy, Data Subjects are Candidates, Employees, Interns, Vendors, Contestants, and Individuals related to Candidates/Employees/Interns/Vendors of NAVER Vietnam.
• 5. Processing of personal data: One or more activities affecting personal data, such as: collecting, recording, analyzing, confirming, storing, editing, disclosing, combining, accessing, retrieving, recovering, encrypting, decrypting, copying, sharing, transmitting, providing, transferring, deleting, destroying personal data, or other related actions.
• 6. Consent of the data subject: A clear, voluntary expression affirming the data subject's permission to process personal data.
• 7. Personal Data Controller: NAVER Vietnam; NAVER Vietnam does not authorize any Third Party to perform the role of Personal Data Controller.
• 8. Personal Data Controller and Processor: The party that simultaneously decides the purposes and means of processing and directly processes personal data.
• 9. Personal Data Processor: The party that performs data processing on behalf of the Data Controller through a contract or agreement with the Data Controller.
• 10. Third Party: Organizations or individuals other than the Data Subject, Personal Data Controller, or Personal Data Processor who are permitted to process personal data. At NAVER Vietnam, a Third Party is a party that signs a contract/agreement with the Data Processor without signing a direct contract/agreement with NAVER Vietnam.
• 11. Personal Data Processing Department/Division at NAVER Vietnam: The Department/Division/Board assigned to perform Personal Data Processing activities at NAVER Vietnam.
• 12. Personal Data Management Department/Division at NAVER Vietnam: The Department/Division/Board assigned to directly store and manage personal data at NAVER Vietnam.
• 13. Receiving and Responding Department/Division: The Personal Data Management Department/Division at NAVER Vietnam corresponding to each type of data subject within the scope of this Regulation.

Article 2

General Provisions

• 2.1. Personal data provided by the Data Subject to NAVER Vietnam and/or obtained by NAVER Vietnam through other actions is understood to include Basic Personal Data and/or Sensitive Personal Data of the Data Subject and individuals related to the Data Subject.
• 2.2. The Data Subject has notified and obtained consent from Individuals related to the Data Subject regarding compliance with this Policy when providing their personal data (including but not limited to dependents, related persons as prescribed by law, representatives, guardians, friends, references, beneficiaries, authorized persons, partners, emergency contacts, etc.) to NAVER Vietnam and shall be responsible if consent from these groups has not been obtained.
• 2.3. The Data Subject has read, researched, and fully understood their rights and obligations, the types of Personal Data being processed, the purpose of processing, and the organizations and individuals permitted to process personal data. The information stated in this Policy is equivalent to a notice from NAVER Vietnam to the Data Subject before NAVER Vietnam proceeds with personal data processing. For sensitive personal data, NAVER Vietnam will notify the Data Subject via email/document regarding the sensitive nature of the data to be processed.
• 2.4. From the time the Data Subject provides personal data to NAVER Vietnam and/or NAVER Vietnam obtains it through other actions until the Data Subject no longer has any transactions/obligations at NAVER Vietnam or according to NAVER Vietnam's decision (whichever occurs later), NAVER Vietnam is permitted to process the Data Subject's personal data for the following purposes in ways NAVER Vietnam deems necessary and not contrary to law:
  1. Contacting for confirmation, updating information, supporting candidates in taking tests/performing next steps in the recruitment process.
  2. Updating Employee information on NAVER Vietnam's HR and C&B (Compensation & Benefits) systems; performing employer obligations for new employees, including recording employee IDs, levels, positions, salaries, and allowances; opening bank accounts; procedures with social insurance and tax authorities.
  3. Performing NAVER Vietnam's rights and obligations under contracts/agreements and legal regulations.
  4. Entering/storing/retaining collected information in NAVER Vietnam's software and technology systems for tasks such as: post-recruitment information transfer, performing services under contract including answering queries, troubleshooting, and fulfilling requests from competent state agencies during inspections.
  5. Organizing training and evaluating performance as agreed upon between the Data Subject and NAVER Vietnam.
  6. Supporting and ensuring the Data Subject can exercise their rights according to law.
  7. Storing personal data on systems of storage service providers.
  8. Checking, testing, installing, managing, upgrading, and improving technical aspects and personnel in charge of security systems to protect Data Subject information.
  9. Promoting, introducing, and informing the Data Subject about services, recruitment programs, research, surveys, news, updates, events, contests with prizes, and event programs.
  10. Contacting, evaluating, and processing requests from the Data Subject, including responding to queries or feedback, resolving or investigating any complaints, legal requests, or disputes, or exchanging information and providing documents as requested by the Data Subject.
  11. Implementing measures to ensure safety, security, and protection of Data Subject data against harm or risks of harm; serving storage, management, protection, and information safety work.
  12. Resolving disputes, complaints, and denunciations.
  13. Providing and exchanging information with competent state agencies and other organizations/individuals in accordance with the law.
  14. Performing promotional advertising for surveys and contests organized or co-organized by NAVER Vietnam.
  15. Other purposes as assessed by NAVER Vietnam from time to time.
• 2.5. The Data Subject confirms, agrees, and commits that:
  1. They have been notified by NAVER Vietnam about personal data processing through this Policy and agree to NAVER Vietnam's collection and processing of data from the time they confirm Consent via website/App/Email/Chat or sign a written consent with NAVER Vietnam until completion of the purposes stated in section 2.4. Withdrawal of consent (if any) shall not affect the legality of data processing agreed upon previously. The Data Subject is fully aware and responsible for all consequences or damages arising from their withdrawal of consent without notice from NAVER Vietnam. If withdrawal of consent is not performed according to law, affecting data processing, NAVER Vietnam may apply necessary measures to protect its legal rights and interests.
  2. If consent is withdrawn, NAVER Vietnam may proactively request Data Processors/Third Parties to stop processing at any time deemed appropriate based on technical infrastructure and capabilities. If withdrawal is not performed according to law or due to technical factors, NAVER Vietnam is exempt from all obligations and responsibilities related to the withdrawal request.
  3. They shall notify and update NAVER Vietnam of any changes to their personal data and agree that NAVER Vietnam has the full right to update and edit the data accordingly.
  4. NAVER Vietnam has the right to manage and retain all obtained personal data in the manner and for the duration it deems appropriate; Data Subjects shall not arbitrarily propose to view, edit, or delete data unless agreed by NAVER Vietnam. NAVER Vietnam has the right to refuse such requests if deemed inappropriate.
  5. If NAVER Vietnam agrees to edit data, it will do so according to technical infrastructure capabilities. If editing is not possible due to technical factors, NAVER Vietnam will notify the Data Subject via email/document after 72 hours from receiving the request and is exempt from related responsibilities.
  6. NAVER Vietnam agrees to delete personal data if:
     (i) the Data Subject finds it no longer necessary for the agreed purposes;
     (ii) consent is withdrawn;
     (iii) the Data Subject objects to processing with justifiable reasons;
     (iv) the Data Subject proves processing is for wrong purposes or violates the law.
     If accepted, NAVER Vietnam will perform the deletion within 72 hours based on technical capabilities, unless otherwise required by law.
  7. NAVER Vietnam is exempt from all obligations and responsibilities regarding risks during processing, including but not limited to data loss due to system errors or objective causes beyond NAVER Vietnam's control.
  8. For processing data of a person declared missing or deceased, consent must be obtained from the spouse or adult children; if unavailable, consent from the parents is required, except as otherwise prescribed by law.
  9. For processing children's data, consent from the child (if aged 7 or older) and the parent or guardian is required, except as otherwise prescribed by law. Customers providing children's data guarantee they have obtained such consent and are responsible for it. NAVER Vietnam will verify the child's age and request necessary consents before processing.
  10. Other organizations/individuals (Data Processors or Third Parties) provided with data by NAVER Vietnam include but are not limited to:
      (i) partners/organizations providing products/services to Data Subjects;
      (ii) those provided for other purposes as assessed by NAVER Vietnam.
  11. To achieve processing purposes, NAVER Vietnam may share data with other related organizations/individuals within or outside Vietnam. NAVER Vietnam will require recipients to ensure data security and confidentiality and ensures compliance with legal obligations regarding data transfer.

Article 3

Rights and Obligations of Data Subjects

• 3.1. Data Subjects have the following rights:
  1. Right to be informed about the processing of their Personal Data (type of data, purpose, participating parties, rights, and obligations).
  2. Right to consent or not consent to processing.
  3. Right to access to view, edit, or request correction of their data, unless otherwise provided by law.
  4. Right to withdraw consent, unless otherwise provided by law.
  5. Right to delete or request deletion of their data, unless otherwise provided by law.
  6. Right to request restriction of processing within 72 hours of the request, unless otherwise provided by law.
  7. Right to request the Data Controller or Controller and Processor to provide their own personal data.
  8. Right to object to processing to prevent disclosure or use for advertising/marketing; the request shall be implemented within 72 hours, unless otherwise provided by law.
  9. Right to complain, denounce, or sue according to law.
  10. Right to claim damages for violations, unless otherwise agreed or provided by law.
  11. Right to self-protection according to the Civil Code and Decree 13/2023/ND-CP. Data Subjects use the Forms attached to this policy to exercise their rights.
• 3.2. Data Subjects have the following obligations:
  1. Protect their own personal data; request related parties to protect their data.
  2. Respect and protect others' personal data.
  3. Provide full and accurate personal data when consenting to processing.
  4. Participate in propagating and disseminating personal data protection skills.
  5. Implement legal regulations on personal data protection and participate in preventing violations.

Article 4

Types of Personal Data Processed by NAVER Vietnam

• 4.1. Basic personal data: Names; date of birth; gender; current residence and contact address; nationality; personal image; phone number, identity card/citizen identity card/passport numbers, tax ID, social insurance book number; information about related persons of the Data Subject; other information helping identify the person (digital accounts, activity history on cyberspace, etc.).
• 4.2. Sensitive personal data: Depending on NAVER Vietnam's policy from time to time.

Article 5

Methods of Collecting Personal Data

NAVER Vietnam collects personal data through activities including but not limited to:

• • Direct verbal or written exchanges.
• • Surveys, social media, or third parties providing related services.
• • Other third parties related to the Data Subject.
• • Files created by NAVER Vietnam's official websites/platforms or those instructed by NAVER Vietnam.
• • Contracts/agreements between NAVER Vietnam and the Data Subject.
• • CCTV surveillance footage.

Article 6

Duration of Personal Data Processing

• 6.1. Start time: Processing starts from the time NAVER Vietnam receives the data.
• 6.2. End time: Processing stops (whichever occurs later) upon:
• • Written request from the Data Subject in accordance with this Policy.
• • Conclusion of disputes/complaints via agreement or legally effective judgment/decision.
• • Other times appropriate to the Purpose or as prescribed by law. NAVER Vietnam may still continue storing data to meet legal obligations and is responsible for its security.

Article 7

Storage and Security of Personal Data at NAVER Vietnam

• 7.1. NAVER Vietnam commits to safe storage and security in compliance with the law. Permitted third parties must comply with NAVER Vietnam's security obligations.
• 7.2. NAVER Vietnam applies appropriate processing methods and technical/organizational security measures to avoid unauthorized access, use, or destruction.
• 7.3. System logs of the processing will be recorded and stored for the purposes in section 2.4 and as required by law.
• 7.4. While appropriate measures are applied, they cannot completely prevent all illegal access by third parties like hackers.
• 7.5. Information safety risks may occur due to the nature of the internet. Data Subjects recognize that NAVER Vietnam is not responsible for risks once the data has been shared with authorized third parties.

Article 8

Amendment, Supplement, and Replacement of Policy

• 8.1. NAVER Vietnam may amend, supplement, or replace this Policy at any time in accordance with legal regulations.
• 8.2. Notifications of changes will be made via document, email, mass media, official website, or posting at headquarters/transaction points.
• 8.3. If no written/email response is received after notification, the Data Subject is understood to have accepted the changes.

Article 9

Contact and Complaints Regarding Personal Data Processing

• 9.1. For queries or rights exercise, please contact:
• • Email: dl_dppnvn@navercorp.com
• • Headquarters: 4th Floor & 9th Floor, Tower B, Viettel Building - 285 Cach Mang Thang Tam St, Ward 12, Dist 10, HCMC.
• • Representative Office: 13th Floor, Radio Frequency Directorate Building, 115 Tran Duy Hung, Yen Hoa Ward, Hanoi.
• • Website: https://www.navercorp.vn/vn/main.html
• 9.2. To exercise rights under Decree 13/2023/ND-CP, visit:
• https://www.navercorp.vn/vn/data_policy.html

Article 10

Dispute Resolution

Disputes shall first be resolved through negotiation and mediation. If mediation fails, disputes shall be brought to a competent Court in Vietnam.

Article 11

Implementation Effect

This Policy is effective from the time it is accepted/agreed upon by the Data Subject. This Policy shall prevail in case of any conflict or contradiction with other agreements or documents governing the relationship between the Data Subject and NAVER Vietnam.