Contents

1. Introduction
2. General Information
3. User Rights In Relation To Personal Information And How To Exercise Them
4. What Personal Information Does PSA Solutions Collect ?
5. How Is Personal Data Collected?
6. Legal Basis For Using Personal Data
7. Disclosures Of Personal Data
8. International Transfers
9. Data Security
10. Data Retention
11. Changes To Our Privacy Policy

This policy is an important document. PSA Solutions recommends that user reads it carefully.

If a user has any questions regarding this Privacy Policy, including any requests to exercise the user’s legal rights, the user can contact PSA Solutions using the following information:

• Full name of legal entity:PSA Solutions CO., LTD
• Email address:hello@psa.com.vn
• Address:A3 building floor 02- Apartment 210, Phan Xich Long street, ward 7, Phu Nhuan district, Ho Chi Minh (Sai Gon) city

User duty to inform PSA Solutions of changes: It is important that the personal data PSA Solutions holds about user is accurate and current. The user should keep PSA Solutions informed if the user’s personal data changes during the relationship between the user and PSA Solutions.

Third-party links: This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about user. PSA Solutions does not control these third-party websites and is not responsible for their privacy statements. When a user leaves the website, PSA Solutions encourages the user to read the privacy notice of every website visited.

In this policy, the terms are used:

• “PSA Solutions” in the Privacy Policy is PSA Solutions CO., LTD
• “Personal Information” or “Personal Data” is any information relating to an identified or identifiable natural person.
• “Identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors.
• “User” and “the user” (and other similar terms) refer to PSA Solutions clients, individuals associated with PSA Solutions clients, contacts, suppliers, job applicants, staff and visitors to the PSA Solutions website https://psa.com.vn/

2. General Information

PSA Solutions values the privacy of user who provide personal information to company. This Privacy Policy aims to give the user information on how PSA Solutions collects and processes their personal data including any data that they may provide through PSA Solutions website.

People under 18 years old will not be considered as PSA Solutions users. The access to PSA Solutions website from them would be considered misuse of PSA Solutions service and PSA Solutions is not responsible for any consequence of such access.

This policy applies to both personal information supplied to PSA Solutions either by an individual or by legal third parties. PSA Solutions may use personal data supplied for any of the purposes as set out in this policy, or as otherwise disclosed at the point of collection.

In particular, PSA Solutions will make sure that all personal data shall be processed in compliance with the following principles:

• Lawfulness, fairness and transparency:To process lawfully, fairly and in a way that is transparent to the data subject.
• Purposes limitation:To collect or create for specified, explicit and lawful purposes and not be further processed in a manner that is not complied with the purposes under this policy.
• Data minimization:To collect personal data in the manner of adequate, relevant and limited to what is necessary for PSA Solutions purposes.
• Accuracy:To reasonably maintain the personal data is accurate and updated.
• Storage limitation:To retain the personal data no longer than the necessity of PSA Solutions purposes, except in the circumstances established by law.
• Integrity and confidentiality:To keep personal data safe from any unauthorized access, processing, accidental or deliberate loss or destruction.

3. User Rights In Relation To Personal Information And How To Exercise Them

• Under certain circumstances users have the following rights:
  • Request accessto the personal data (commonly known as a “data subject access request”). This enables user to receive a copy of the personal data PSA Solutions holds about him / her and to check that PSA Solutions is lawfully processing it.
  • Request correctionof the personal data that PSA Solutions holds. This enables user to correct any incomplete or inaccurate data PSA Solutions holds about him / her.
  • Request erasureof the personal data. This enables user to lawfully request PSA Solutions to delete or remove his / her personal data where there is no good reason for PSA Solutions continuing to process it.
    The user also has the right to ask PSA Solutions to delete or remove the personal data where user has the right to object to processing (see below), where PSA Solutions may have misused his / her information or where PSA Solutions is required to erase the personal data to comply with local law.
    However, that PSA Solutions may not always be able to comply with the request of erasure for specific legal and business reasons which will be notified to the user, if applicable, at the time of the request.
  • Object to processingof the personal data where PSA Solutions is relying on a legitimate interest (or those of a third party) and there is something about the particular situation which makes the user want to object to processing on this ground as the user feels it impacts on his / her fundamental rights and freedoms.
    The user also has the right to object where PSA Solutions is processing the personal data for direct marketing purposes. In some cases, PSA Solutions has compelling legitimate grounds to process the information that override the agreement with the user.
  • Request restriction of processingof the personal data. This enables user to ask PSA Solutions to suspend the processing of his / her personal data in the following scenarios:
    • If user wants PSA Solutions to establish the data’s accuracy
    • Where data usage is misused but user does not want to erase it
    • Where user needs to hold the data even if PSA Solutions no longer requires it as the user needs to establish, exercise or defend legal claims
    • User has objected to PSA Solutions usage his / her data but PSA Solutions needs to verify whether PSA Solutions has overriding legitimate grounds to use it
  • Request the transferof personal data to user or to a third party. PSA Solutions will provide to the user, or the third party, the user’s personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which user initially provided consent for PSA Solutions to use or where PSA Solutions used the information to perform a contract with the user.
  • Withdraw consent at any timewhere PSA Solutions is relying on consent to process user’s personal data. However, this will not affect the lawfulness of any processing carried out before the user withdraws his / her consent. In this case, PSA Solutions may not be able to provide certain products or services to user. PSA Solutions will advise user at the time user withdraws his / her consent.
  • If user wish to exercise any of the rights set out above, please contact PSA Solutions via email at hello@psa.com.vn
• No fee usually required:User will not have to pay a fee to access the personal data (or to exercise any of the other rights). However, PSA Solutions may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, PSA Solutions may refuse to comply with the request in these circumstances.
• What PSA Solutions may need from user:PSA Solutions may need to request specific information from user to identity and ensure user’s right to access the personal data (or to exercise any of user rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to access it. PSA Solutions may also contact you to ask you for further information in relation to your request to speed up our response.
• Time limit to respond:PSA Solutions tries to respond to all legitimate requests within one month. Occasionally it may take longer than a month to process the requests. In this case, PSA Solutions will notify user about the processing time.

4. What Personal Information Does PSA Solutions Collect ?

PSA Solutions aims to be transparent about why and how PSA Solutions processes personal information.

• For all visitors to the PSA Solutions website, PSA Solutions may collect, use, store and transfer different kinds of personal data which PSA Solutions has aggregated as follows:
  • Identity Dataincludes first name, last name, user name or similar identifier, title, and gender.
  • Contact Dataincludes address, email address and telephone numbers.
  • Technical Dataincludes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Dataincludes user name, interests, preferences and feedback.
  • Usage Dataincludes information about how user uses PSA Solutions website, products and services.
  • Communications Dataincludes data user sent to PSA Solutions via PSA Solutions website, email or chat box.
• In addition, if user is a candidatebeing considered for a role or any opportunities
  • PSA Solutions may also collect other information including in the candidate’s CV / resume as well as other details about kills and experience, career history, salary range, right to work status, any information which has been published or made available on a social media profile or job board (whether by user or a legal third party), or in any news media.
• PSA Solutions may also collect need information to complete a contract for candidate such as:
  • Bank account.
  • A copy of passport details including passport photograph.
  • Recruitment-specific details such as any professional certifications, education and qualifications.
  • Referees and emergency contacts including full name, address, email address and telephone number.
  • References from third parties such as previous employers and nominated referees.
  • The results of pre-employment screening or vetting checks which PSA Solutions is asked or required to undertake in relation to you.
  • Any email communications, including attachments, which candidate sends to PSA Solutions.
  • General health-care checkup information.
  • Any other information relevant required by law.
• Where user is a customer, PSA Solutions may collect more information from or about his / her, including:
  • Details of role, title and responsibilities within his / her organization.
  • Any opinion or feedback shared regarding PSA Solutions product / service.
  • Details of any queries raised regarding PSA Solutions products / services.
  • Any email communications, including attachments, which are sent to PSA Solutions.

5. How Is Personal Data Collected?

PSA Solutions uses different methods to collect data from and about user including through:

• Direct interactions:User may give PSA Solutions the identity and contact data by filling in forms or providing other information via PSA Solutions website hello@psa.com.vn or email @pixa.vn. This includes personal data provided when:
  • Request PSA Solutions products / services.
  • Respond to a recruitment posted by PSA Solutions on job advertisement services.
  • Request marketing or providing services.
  • Give PSA Solutions some inquiries / feedback.
• Automated technologies or interactions. As user interacts with PSA Solutions website, it may automatically collect data about the user’s equipment, browsing actions and patterns… Such technical data might reveal certain types of personal data by using cookies, server logs and other similar technologies. Please see PSA Solutions Cookies Policyfor further details
• Third parties or publicly available sources:PSA Solutions may receive personal data from various third parties and public sources that have legal permission to share the information. They are listed below but not limited to:
  • Analytic providers [such as Google based outside the EU]. For more information on Google’s use of the personal information, please see Types of Cookies Used by Google.
  • Social network sites: LinkedIn, publicly available on job board (whether by user or a legal third party).

6. Legal Basis For Using Personal Data

PSA Solutions will only use the personal data for lawful purposes. Commonly, PSA Solutions will use the personal data in the following circumstances:

• Where it is necessary to perform business contract between PSA Solutions and user.
• Where it is necessary for PSA Solutions legitimate interests (or those of a third party), user’s interests and fundamental rights do not override those interests.
• Where it is necessary to comply with any legals or regulatory obligations.

The possible ways, which PSA Solutions plans to use personal data, have set out below:

• Providing Services: In this regard, PSA Solutions may collect, process, and disclose personal data for the purpose of:
  • Assessing of the suitable candidate for particular positions or employment roles as defined by customer.
  • Evaluating and assessing of the suitability for providing resourcing, outsourcing or consultancy.
  • Matching a candidate details with vacancies of PSA Solutions and / or customer.
  • Disclosing a candidate’s personal data to customer for positions or employment role as defined by customer.
• Maintaining records of any and all candidate, consultant, customer, business partner, supplier, staff, and staff of third-party supplier.
• Administering and carrying out relationship management procedures of customer and prospective customer.
• For internal management, accounting, and employment purposes of PSA Solutions.
• Conducting marketing, profiling, and business development activities as well as market research and statistical analysis and customer survey regarding PSA Solutions services.
• Complying with any legal or regulatory requirements and to make the necessary disclosure under the requirements of any law, regulation, direction, court order, or code which are applicable to PSA Solutions.

Note that PSA Solutions may process the personal data for more than one legal basis depending on the specific purposes. User has the right to withdraw his / her consent by contacting PSA Solutions via hello@psa.com.vn

7. Disclosures Of Personal Data

PSA Solutions may have to share personal data with the legal parties below for the purposes set out in the section 6 above:

• Third-party service providers:When PSA Solutions shares the personal data with any third-party service providers to facilitate and support PSA Solutions in the provision of the services. This includes, but not limited to:
  • IT service providers.
  • Payment processors.
  • Third party partners for the purposes of hosting events.
• Outsourcing services:When PSA Solutions is using the personal data in the context of recruitment and outsourcing services, then PSA Solutions may share the personal data with customers, or where PSA Solutions believes that the candidate may be appropriate for a particular role or vacancy with that customer is hiring with the candidate / employee’s permission.
• Umbrella / group companies:The personal data may be provided to PSA Solutions subsidiaries or affiliated companies for the purpose of processing personal data on behalf of PSA Solutions to provide products / services. These parties are required to process such data based on PSA Solutions’s instructions and in accordance with this Privacy Policy. They do not have any independent right to share such data.
• Compliance with laws and legal proceedings:When PSA Solutions responds to court orders, or legal process, or to establish or exercise PSA Solutions legal rights or defend against legal claims. When PSA Solutions believes that it is necessary to share data in order to investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of PSA Solutions terms of use, or as otherwise required by law.

8. International Transfers

PSA Solutions will be entitled to disclose personal data to any third parties, and / or transferred either internally or outside of Vietnam, for the purposes as listed in the section 6 above of this policy when the consent thereof has been obtained in advance.

PSA Solutions would like to make sure that personal data is stored and transferred in a way which is secure. Thus, PSA Solutions will only transfer data to third-parties where they comply with the data protection legislation and the means of transfer safeguards.

9. Data Security

PSA Solutions has put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, PSA Solutions limits access to the personal data to those employees, contractors and other third parties who have a business that requires the corresponding personal data. They will only process the personal data based on an agreement with PSA Solutions in which, among other constraints, they are subject to a duty of confidentiality.

PSA Solutions also has put in place procedures to deal with any suspected personal data breach and will notify user and any applicable regulator of a breach where PSA Solutions are legally required to do so.

10. Data Retention

PSA Solutions does not keep data longer than necessary.

• For most users where PSA Solutions has limited contact, PSA Solutions will retain the personal data for maximum of two years from the date of last contact.
• Where PSA Solutions has business contract with user, for instance PSA Solutions has worked with user as a customer, the personal data will be kept for 10 years.
• Where PSA Solutions has interviewed / placed user as a candidate, the personal data will be kept for 5 years.
• In all cases listed above, PSA Solutions may retain data longer. In this case, PSA Solutions will notify user about the change of data retentionPSA Solutions

PSA Solutions will delete personal data after that time except where PSA Solutions needs to keep any personal data to comply with legal obligations, resolve disputes, or enforce agreements.

11. Changes To Our Privacy Policy

This Privacy Policy was last updated on 31/10/2018.

Please check back regularly to keep informed of updates to this Privacy Policy. Where PSA Solutions makes significant changes to this Privacy Policy and has user’s email address, PSA Solutions will send user notification of the changes.