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Privacy Policy

Talent Recruitment Joint Stock Company ("TRCJSC") and/or its subsidiaries, including but not limited to branches, representative offices, business locations, and/or subsidiary companies of TRCJSC ("TRCJSC" or "We"), solemnly pledge to respect privacy rights and protect your personal data.

The Personal Data Processing and Protection Policy ("Policy") elucidates how We handle and safeguard your Personal Data in relation to candidate search processes and TRCJSC's recruitment programs for Third Parties (as defined in Section 1.6), who are partners and/or clients in need of candidate search services ("Services''). This Policy only applies to the Personal Data of job applicants, potential candidates for employment, or partners, and those who engage in providing Our Services.

By choosing to sign in Data Protection Agreement and agree to the Policy when registering for an account, or giving your consent through your personal email, and/or through any other suitable form as prescribed by law, you have read, comprehended, and consented to the processing of your Personal Data as stated in this Policy, and TRCJSC is not obligated to provide prior notice before processing your Personal Data.

1.Definitions and Explanations

1.1. "Policy" refers to the Personal Information Privacy Policy and any accompanying documents by reference, which may be modified as per the provisions of this Policy;

1.2. "You" or "Data Subject" refers to the individual whose personal data is reflected, including all candidates, individual customers using services provided by TRCJSC, and/or other individuals related to or arising from service provision or other legal relationships with TRCJSC.

1.3. “TRCJSC”: is the Talent Recruitment Joint Stock Company and/or its subsidiaries, including but not limited to branches, representative offices, business locations, and/or subsidiary companies (if any).

1.4. "Personal Data" means digital data or information in other forms that identifies or assists the identification of a specific individual, including basic personal data and sensitive personal data specified in Sections 1.4.1 and 1.4.2 below. Personal data, once de-identified, is no longer considered personal data:

1.4.1. Basic personal data: These are personal data reflecting common personal details and background information that You provide to TRCJSC when using its services, including but not limited to: Last name, first name, middle name, other name (if any); Date of birth; Date of death or missing; Gender; Place of birth, place of birth registration, place of permanent residence registration, place of temporary residence registration, current place of residence, hometown , contact address; Nationality; Personal image; Phone number, personal identification number, passport number, driver's license number, vehicle license plate number; Marital status; Information about family relationships (parents, children, spouse); Information about individual’s digital account ; Other information associated with a specific individual or capable of identifying a specific individual, other than the information prescribed in Section 1.4.2 below;

1.4.2. Sensitive personal data: These arepersonal data associated with individuals’ privacy rights , including but not limited to: Data revealing racial origin or ethnic origin; Opinions on politics, religion, and belief; Information on private life, personal secrets, and family secrets; Healthstatus; Biometric data and genetic characteristics; Data revealing an individual’s sexual life or sexual orientation; Data on crimes and violations of law collected and stored by law enforcement agencies; Location data of individuals determined through positioning services; Login names and passwords for access to individuals’ electronic identification accounts; Images of ID cards, citizen ID cards, or 9-digit ID card; Login names and passwords for access to bank accounts; Bank card information; data on transaction history of bank accounts; financial and credit information and other information relating to financial activities and transaction history, securities, and insurance of clients at credit institutions, foreign bank branches, intermediary payment service providers, securities institutions, insurers, and other authorized organizations; Data monitoring behavior and activities related to the use of telecommunications services, social networks, online communication services, and other services in cyberspace; Other personal data that are required by law to be kept confidential or to which strict confidentiality measures must be applied.

1.5. "Processing of Personal Data" means activities impacting personal data, including one or more of the following: collection, analysis, summary, encryption, decryption, modification, deletion, destruction, de-identification, provision, disclosure, transfer of personal data, and other activities impacting personal data.

1.6. "Third Party'': These are individuals, organizations not part of TRCJSC and legally bound to TRCJSC through contracts, agreements, or other commitments, including but not limited to customers, businesses, organizations in need of recruiting candidates for themselves.

2.General Provisions:

2.1. This Policy shall encompass:

  • The types of Personal Data processed by TRCJSC and the methods of processing such Personal Data;
  • The purposes of processing Personal Data;
  • The organizations and individuals related to the Processing of Personal Data;
  • The rights and obligations of the Data Subject and TRCJSC concerning the Processing of Personal Data;
  • The potential consequences and damages that may occur, along with the commencement and termination period of the Processing of Personal Data.

2.2. This Policy also regulates and governs the processing of personal data by:

  • Other relevant parties as determined by TRCJSC at different times: dependents, spouses, children, parents, authorized individuals, emergency contacts, and other individuals ("Related Parties").
  • By providing your personal data and/or the personal data of Related Parties to TRCJSC, you certify and warrant that: (i) you have obtained the consent of the relevant Related Party for the processing of Personal Data under the terms and conditions set out in this Policy, and (ii) you assume full responsibility for TRCJSC's processing of the personal data of the Related Party that you provide to TRCJSC.

2.3. The provisions regarding the Processing of Personal Data set forth in this Policy may be updated, amended, supplemented, or replaced by TRCJSC at different times, and shall be published by TRCJSC on the official electronic information page of TRCJSC (https://www.hr2b.com ) and will be notified to You through other appropriate means of TRCJSC;

2.4. The provisions regarding the processing of Personal Data in this Policy are an integral and inseparable part to be read and consistently understood with any contracts, agreements, terms, conditions, and other documents established between the Data Subject and TRCJSC (if any);

2.5. By allowing TRCJSC to Process Personal Data, You fully understand and unconditionally accept all the terms referenced in this Policy and any subsequent changes (if any) thereto; and

2.6. Your Personal Data may be transferred and processed outside the territory of Vietnam (including but not limited to activities involving the use of the internet, devices, electronic means, or other methods to transfer Personal Data outside the territory of Vietnam), for the Purposes and in the manner prescribed in this Policy. TRCJSC commits to fully comply with the regulations and compliance requirements of Vietnamese law to ensure the safety of Personal Data.

3.Purpose of Processing Personal Data

With the aim of entering into, executing, managing, and terminating the performance of Services between You and TRCJSC and/or for the purposes of business, operation, management, and business activities of TRCJSC (hereinafter referred to as the "Purpose"), TRCJSC may Process Personal Data for the Purpose, including but not limited to the following Purposes

3.1. To identify, verify, and maintain accurate information about the Data Subject, including managing Your registered account on TRCJSC's website and/or the Personal Data You provide during the provision of Services;

3.2. To evaluate, select, recruit suitable candidates as per the requirements of Third Parties and/or handle related matters such as proposing job opportunities to You with Third Parties; conducting procedures and processes to arrange for the Data Subject to work with Third Parties; fulfilling declarations and reports to the authorities as required by law (if any);

3.3. To contact the Data Subject, including but not limited to sending information to you via telephone, email, or messages. The Data Subject agrees that during such communication, TRCJSC and/or Our personnel may lawfully disclose some information about Personal Data to ensure that You receive information from Us;

3.4. To disclose Personal Data on the TRCJSC website and/or provide Personal Data, to the extent permitted by applicable law, to other employers and/or Third Parties to create opportunities for You to find employment;

3.5. To store records of the Data Subject related to recruitment and/or the performance of Services, responding to legal requests from relevant Third Parties related to Your Personal Data;

3.6. To collect opinions of the Data Subject through surveys about the Services provided by TRCJSC or to perform statistical analysis related to the activities of TRCJSC;

3.7. To comply with court requirements or other legal procedures or other legal requirements and/or regulations of any government and/or management agency;

3.8. To perform internal administration, risk management, and compliance activities of TRCJSC, including but not limited to serving the needs of internal operations of TRCJSC or its subsidiaries;

3.9. To develop, manage and implement welfare, benefits and employee engagement programmes and policies for the Data Subject, including TRCJSC company trips, birthday events, internal activities and other welfare programmes;

3.10. To record and use the Data Subject’s images, videos and related information for TRCJSC’s communication, promotional, marketing, event-related and branding activities on internal and public communication channels, to the extent consented to by the Data Subject under this Agreement;

3.11. To ensure the legitimate business purposes of TRCJSC in cases where TRCJSC deems it necessary, including but not limited to exchanging information with Third Parties and/or complying with agreements, legal contracts between TRCJSC and other Third Parties;

3.12. To verify the completeness and accuracy of data provided by the Data Subject to TRCJSC;

3.13. To fulfill reporting, financial, accounting, and tax obligations and perform auditing, risk management, and compliance activities of TRCJSC and/or Third Parties (if any); and

3.14. Any purpose described for the Data Subject at the time of collecting Personal Data of the Data Subject.

4.Provision of Personal Data

To the extent permitted by applicable law, to carry out the Purposes and activities of processing Personal Data under this Policy, TRCJSC may provide Personal Data to the following parties, provided that TRCJSC implements the necessary security measures to protect Your Personal Data during such transfer or sharing:

4.1. Any Third Party on behalf of TRCJSC to carry out activities related to the Processing of Your Personal Data to fulfill the Purposes stated in Section 3 above;

4.2. Any service providers, consultants, or parties cooperating with TRCJSC (including but not limited to employees, directors, executives); organizations as sellers, suppliers, partners, agents including but not limited to companies providing services, supporting the business operations of TRCJSC and/or Third Parties such as administrative service providers, recruitment agencies, human resources management, data processing, information technology, market research services, consulting services, and/or other relevant services to support the business operations of TRCJSC and Third Parties;

4.3. Any subsidiaries of TRCJSC and/or Third Parties; subsidiaries, joint ventures, affiliates identified by TRCJSC and Third Parties at different times;

4.4. Other relevant parties deemed necessary by TRCJSC to meet, protect the legitimate rights and interests of the Data Subject, TRCJSC, and Third Parties under legal agreements between Third Parties and TRCJSC;

4.5. Advisors and/or professional consulting companies of TRCJSC and/or Third Parties, including but not limited to accountants, auditors, lawyers;

4.6. Parties in transactions/anticipated transactions of purchase, sale, transfer, transfer of business and/or assets of TRCJSC (if any);

4.7. Any individual, competent authority or government agency or third party that TRCJSC is allowed or required to disclose under the provisions of the law or under any other legal contract or commitment between Third Parties and TRCJSC;

4.8. Any court, arbitrator, court of jurisdiction/court of execution that has authority/is required to enforce responsibilities from TRCJSC;

4.9. Other organizations, individuals as required by law;

4.10. Due to the scope of TRCJSC's operations, sharing Your Personal Data with organizations, service providers, and customers deemed as Third Parties may lead to Your Personal Data being sent to Third Parties outside the territory of Vietnam. Regardless of the location, TRCJSC will always protect Your Personal Data as described in this Policy and according to the current regulations of the law; and

4.11. Any party that TRCJSC deems necessary for the purposes of processing personal data as described in Article 3.

5.Rights and Obligations of Data Subjects

5.1. Except as stated in Section 5.3 below, TRCJSC respects and endeavors to safeguard the following rights of Data Subjects: the right to be informed of the personal data processing; consent, refuse, or request withdrawal of consent to the personal data processing; view, modify, or request modification of their personal data; request provision, deletion, and restriction of personal data processing; object to personal data processing; complain, denounce, initiate lawsuits, or claim damages according to the law; request competent authorities or agencies, organizations, or individuals relevant to personal data processing to adopt solutions and measures to protect their personal data according to the law.

5.2. Obligations of Data Subjects: to safeguard their personal data; respect and protect the personal data of others; provide complete and accurate personal data when consenting to TRCJSC and/or Third Parties to process personal data or under a contract or comply with personal data protection laws; comply with applicable personal data protection laws, participate in preventing and combating infringements of Personal Data, and fulfil other obligations as required by applicable law.

5.3. To clarify, the rights of Data Subjects as mentioned in Section 5.1 above may be limited and/or TRCJSC has the right to refuse to fulfill the requests of Data Subjects in the following cases:

5.3.1. The requests of Data Subjects are unreasonable according to the provisions of the law or affect the legitimate rights of TRCJSC;

In case the Data Subject withdraws their consent, requests data erasure, and/or exercises other related rights regarding any or all Personal Data that affects TRCJSC's ability to provide/maintain services to the Data Subject and/or Third Parties, depending on the nature of the Data Subject's request, TRCJSC may consider and decide not to continue providing TRCJSC's services to the Data Subject;

5.3.2. The Data Subject does not provide or provides incomplete, fraudulent documents, materials to verify identity, and/or in cases where TRCJSC assesses signs of fraud, non-compliance with the agreements in this Policy, or the provisions of the law on personal data protection;

5.3.3. The provisions of the law do not allow implementation according to the Data Subject's request; and

5.3.4. Other cases under the agreement of both parties or according to the provisions of the law.

6.Rights and Obligations of TRCJSC

6.1. Rights of TRCJSC:

6.1.1. Control, process Personal Data as mentioned in section 1.4 of this Policy according to the stated Purpose;

6.1.2. In case the Data Subject provides untruthful and/or non-compliant Personal Data according to the agreed-upon agreements in this Policy or violates the provisions of the law that affects TRCJSC's ability to provide/maintain services to the Data Subject and/or Third Parties, TRCJSC may consider and decide not to continue providing TRCJSC's services to the Data Subject. In that case, TRCJSC shall not be liable for any losses incurred by the Data Subject, and TRCJSC's legal rights shall be clearly reserved with respect to limiting, restricting, suspending, canceling, and preventing such Personal Data.

6.2. Obligations of TRCJSC:

6.2.1. Implement protective measures for Personal Data with effort and a sense of responsibility, regularly review, update to ensure the rights of Data Subjects are not affected;

6.2.2. Process Personal Data securely, comply with the provisions of the law on the protection of Data Subjects' Personal Data;

6.2.3. Notify violations of the provisions on personal data protection as required by law;

6.2.4. Cooperate with the Ministry of Public Security, authorized state agencies in the protection of Personal Data, provide information to serve the investigation, handling of violations of the provisions of the law on personal data protection;

6.2.5. Promptly respond, within two (2) working days from receipt of a valid request from a Data Subject to exercise the rights set out in Section 5.1, provide the Data Subject with the necessary information regarding the procedures for handling such request, and fulfil the request within the applicable time limit prescribed by law; and

6.2.6. Other obligations as required by the current provisions of the law.

7.Time and Retention of Personal Data

7.1. Processing Period of Personal Data: Depending on the specific activities for the aforementioned Purposes, Personal Data may be processed by TRCJSC and/or Third Parties after being provided, collected, and concluded upon the completion of processing data in accordance with the intended purpose or until Personal Data has been erased as required and/or requested by the current law or the Policies of the Parties.

7.2. Following the termination of the Services, You agree that TRJSC may continue to retain and process Personal Data to the extent and for the period necessary to comply with applicable law or as otherwise agreed by the parties from time to time. Upon expiry of the applicable retention period, where there is no longer a lawful basis for continued retention, TRJSC will delete, destroy or otherwise appropriately handle Personal Data in accordance with applicable law.

7.3. Storage and cross-border transfer of Personal Data: Within the scope permitted by law, Personal Data will be stored and processed in Vietnam or abroad, including cloud storage solutions. TRCJSC will only transfer Personal Data of the Data Subject abroad when it complies with the provisions of the law on personal data protection.

7.4. Information about other organizations and individuals related to the Purpose: Personal Data may be shared with employees within TRCJSC and/or Third Parties, including but not limited to employees, management levels, and related departments to support the implementation of the Purposes.

8.Collection and Processing of Personal Data

Depending on the purpose of processing Personal Data, TRCJSC or the data processor of TRCJSC or Third Parties may collect and process Personal Data through appropriate methods, including but not limited to automatic collection, manual processing, or other methods in compliance with the provisions of the law and of TRCJSC and/or the legal agreement between TRCJSC and Third Parties for each period, specifically:

8.1. Through the established relationship between TRCJSC and the Data Subject when the Data Subject registers, uses any TRCJSC Services;

8.2. From electronic pages, TRCJSC's websites and/or communications between the Data Subject and TRCJSC;

8.3. From interactions or automatic data collection technologies: including IP addresses, referring URLs, operating systems, email clients, and any other information obtained from these systems;

8.4. Through receiving personal data from other Third Parties. TRCJSC, the relevant Third Party, commits and confirms that they have obtained the Data Subject's consent for: (i) providing personal data to TRCJSC; and (ii) processing data for TRCJSC's purposes according to this Policy; and

8.5. From state agencies, competent authorities in Vietnam, and/or other sources as prescribed and permitted by law.

9.Consequences, Unintended Damages that May Occur

Processing Personal Data always carries the risk of data leakage or improper data handling. TRCJSC is aware of the importance and responsibility of protecting Personal Data, committing to apply appropriate protective measures as required by the current law and regularly reviewing, updating the optimal technical measures to ensure safety in processing Personal Data, making maximum efforts to prevent risks and limit any unintended consequences, damages that may occur, protecting the lawful rights and interests of the Data Subject and TRCJSC.

10.Other Agreements

10.1. By choosing to confirm and agree to this Policy when registering an account or confirming consent through your personal email or by any other means in accordance with the provisions of the law, the Data Subject acknowledges that they have been informed, aware, and agree to all the contents that need to be notified before TRCJSC processes Personal Data, as detailed in this Policy. The Data Subject agrees that TRCJSC does not need to re-notify before processing Personal Data, except where otherwise mandatorily required by applicable law;

10.2. This Policy is governed and interpreted under the provisions of Vietnamese law. You understand and agree that this Policy may be amended from time to time. Any amendments will be updated and communicated directly to You through appropriate channels and methods before taking effect, in accordance with applicable law. If You continue to register for or use the Services, You will be deemed to have accepted such amendments, except where TRCJSC is required by law to obtain your consent to such amendments;

10.3. The Parties acknowledge that they have read, understood, and agreed to be bound by all the provisions and conditions of this Policy. Any matters not provided for in this Policy shall be governed by applicable law, guidance issued by competent state authorities and/or amendments or supplements to this Policy made from time to time; and

10.4. In the event of a dispute, the Parties shall first seek to resolve it through good-faith and cooperative negotiations. If the dispute cannot be resolved through negotiation, either Party may refer it to a competent authority for resolution in accordance with applicable law.

11.How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

12. Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website.

Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

13. Children

HR2B is not intended for children under 15 years of age. We do not knowingly collect personal information from children under 15.

14.Contact Information

In case the Data Subject has any questions related to this Policy, please contact us:

HR2B TRJSC

Email: contact@hr2b.com

1st Floor, Thien Son Building

5 Nguyen Gia Thieu Str., Dist. 3

Ho Chi Minh City, Vietnam