Effective Date: 4th of April 2024 1. PURPOSE OF THIS PRIVACY NOTICE
This Privacy Notice (“Privacy Notice”) sets out how TBWA\ Group Vietnam processes your personal data in connection with our business, including the provision of our website at https://www.tbwa.com.vn/ (“Site”) and the services we offer (“Services”).
In particular, this Privacy Notice explains our approach to any personal data that we might collect from you (i) when you use our Site or Services (ii) during any other interactions with us, or (iii) which we might otherwise process when providing Services to our clients (including the personal data we collect, why we collected it and your rights in respect of our processing of your personal data).
This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand this Privacy Notice. It is intended to be read in conjunction with our Terms of Use and Cookie Notice.
Finally, this Privacy Notice is intended to meet the requirements of the legal requirements on the protection of natural persons with regard to the processing of personal data.
2. SCOPE OF THIS PRIVACY NOTICE
This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links on our Site to third party websites over which we have no control).
Further, this Privacy Notice is not intended to cover the processing of workplace personal data. Accordingly, if you are engaged as a worker for us, please see our Workplace Privacy Notice which sets out further information about how we may process your personal data in connection with your employment and/or engagement.
3. CHANGES TO THIS POLICY
We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data. If we update this Privacy Notice, we will update the effective date at the top of the page.
4. ABOUT US
The Site and Services are made available by various companies in the TBWA\ Group Vietnam group of companies (each a “Group Company”).
Where this Privacy Notice refers to “TBWA\ Group Vietnam”, “we”, “us, “our”, this means one or more of the particular Group Companies that provide the particular Site or Services.
Except as stated otherwise, each Group Company is an independent controller of your personal data. The Group Companies are companies incorporated under the laws of Vietnam, with its registered office in Ho Chi Minh City, Vietnam.
For the purpose of this Privacy Notice, unless we state otherwise we shall be considered a data controller of your personal data in connection with use cases identified in this Privacy Notice. Please note that in many cases where we process data in relation to Services that we provide, we may carry out the activities referred to in this Privacy Notice in our capacity as a data processor acting on behalf of our clients. We have made this distinction clear in the Privacy Notice.
5. HOW TO CONTACT US
If you have any questions about this Privacy Notice or want to exercise your rights as a data subject set out in this Privacy Notice, you can contact us using the following methods:
| Send us an email at: privacy@tbwa.com.vn | |
| Post | Write to us at: 7th Floor, No. 195 Dien Bien Phu, Ward 15, Binh Thanh District, Ho Chi Minh City, Vietnam |
| Telephone | Call us on: +84.28.38 245 315 |
6. TYPE OF PERSONAL DATA WE COLLECT/PROCESS
When we talk about personal data, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. Categories of personal data we may collect and process about you include:
| Identity Data | First name; last name. |
| Contact Data | Delivery address; billing address; email address; telephone number; social media handle. |
| Applicant Data | Date of birth; gender; nationality; CVs, work experience any other personal data that you may provide in advance of/during your supply of services to us. |
| Image Data | Photos; video recordings. |
| Financial Data | Bank account details; partial payment card details. |
| Transaction Data | Details about payments made between you and us; details of services purchased from us. |
| Profile Data | Interests and preferences; contact preferences; whether you have participated in any promotions or competitions; feedback and survey responses; the content of any messaging you send using any Enquiry Form or Chat function on the Site. |
| Behavioural Data | Data relating to your browsing activity, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; details about any services you viewed or purchased through the Site. |
| Technical Data(Sensitive personal data) | IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device. |
| Marketing and Communications Data | Marketing preferences; service communication preferences. |
| Publicly Available Data | Information about articles (or similar) that you may have published; Information about your interests or affiliations or publicly stated positions on corporate matters and similar. |
For more information about the personal data, we collect please refer to section ‘HOW WE USE PERSONAL DATA’ below.
7. HOW WE COLLECT PERSONAL DATA
We may collect and receive your personal data using different methods:
| Personal data you provide to us | You may give us your personal data directly, for example, when you obtain services via our Site, contact us with enquiries, complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us. |
| Personal data we collect using cookies and other similar technologies | When you access and use our Site, we will collect certain Behavioural Data and Technical Data. We collect this personal data by using cookies and other similar technologies (see the “website insight and analysis” section below). |
| Personal data received from third parties | We may receive personal data about you from third parties. Such third parties may include third parties that provide technical services to us so that we can provide our Site and our Services. |
| Publicly available personal data | From time to time, we may collect personal data about you (Identity Data, Contact Data, or Publicly Available Data) that is contained in publicly available sources (including open-source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms). |
8. WHO WE COLLECT PERSONAL DATA ABOUT
We collect and process personal data from the following people:
| Site visitors | We will collect and process your personal data in connection with your interaction with us and our Site. |
| People who contact us with enquiries | If you contact us with an enquiry through our Site, submit a complaint or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal data in connection with your interaction with us and our Site. |
| Client personnel | We may collect and process your personal data in connection with the supply of services to you and/or your organization. This may include personal data included in any email or telephone communications or recorded on any document relating to an order for the products or services, such as your Contact Data or your title.Clients should ensure their employees are aware that their data is being shared with us, as described in this policy. |
| Talent | If you supply services and/or content to us and/or work with us to provide services to our client (including featuring in content we produce), we may collect or process your personal data, such as your Identity Data, Contact Data, Financial Data, CVs in connection with such supply of services and/or content to us and our clients. |
| Partner/supplier personnel | If you (or your organisation) supply products or services to us or otherwise partner with us, we may collect and process your personal data in connection with our receipt of those products and services and/or partnership. This may include personal data included in any email or telephone communications or recorded on any document relating to an order for the products or services, such as your Contact Data or your title.Partner and Supplier should ensure their employees are aware that their data is being shared with us, as described in this policy. |
| Visitors to our offices, studios, production sites | If you attend one of our physical offices or other locations, we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when signing in as a guest, or when you register for and access our guest Wi-Fi network at our premises. CCTV footage may also be collected for security purposes. |
| Event attendees | If you attend one of our events, we will process personal data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, or other documents relating to the event. |
| Job applicants | If you apply for a job with us or otherwise express an interest in working for us, or we identify you as a potentially suitable candidate for one of our job openings, we will collect contact details and CV or resume information from you through a range of methods including online job sites, via email, in person at interviews and/or by any other method. |
| Members of the public | We may process your data in connection with the provision of the Services to our clients. |
9. HOW WE USE PERSONAL DATA
A: OPERATION OF SITE, PROVISION OF SERVICES AND MARKETING
I. Operation of the Site
If you browse our Site
When you browse our Site, we collect and process Behavioural Data and Technical Data to help us understand how you are using and navigating our Site. We do this so that we can better understand which parts of our Site are more or less popular and improve the structure and navigation of our Site.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Site in a secure and effective way and so that we can make improvements to our Site.
Website insight and analysis
We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access our Site. The data that is collected includes Behavioural Data and Technical Data, and certain Profile Data. Please see our Cookie Notice for further information, including details of our third-party partners.
We and our third-party partners use this data to analyse how you use our Site and our Services and the effectiveness of our Site and Services, including:
Our legal basis for processing
Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.
In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through the use of analytics cookies to analyse how you use our Site, it is in our legitimate interest to use your personal data in such a way to improve our Site and Services.
If you use the interactive features on our Site
We will collect and use personal data about you when you use certain features on our Site. For example, depending on the nature of your enquiry, we may process your Identity Data, Contact Data, Registration Data, Profile Data and certain Behavioural Data and Technical Data when you use the Enquiry Form or Chat function to get in touch with us or other account holders, or so that you can be searched for by other account holders.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest to use personal data in such a way to ensure that we can respond to your enquiries, provide access to our Site in a secure and effective way and make improvements to our Site.
If you contribute to our Site or post content on our Site
If you write an article or blog for us or contribute in any other way to publications, we send to our account holders and/or publish on our Site or in print, we may use your personal data (such as your Identity Data and/or Contact Details) to credit you for your contribution. If you provide photographs or other images in support of your article or blog, we may publish one or more of those images alongside your article or blog.
If you submit any other content to us, including via our Site, such as photographs, quotes or testimonials, we may process any personal data comprised within that content for the purposes of making available particular Services via our Site and promoting our Site and our Services.
We may also allow third parties to use the articles or blogs that you contribute, or the content that you provide. If the use of such content would involve the use of your personal data, we may use your Contact Details to ask your permission to use the relevant content, unless we are satisfied that we have a lawful right to use the content without your permission.
Our legal basis for processing
Where we use your content in connection with Services that we provide via our Site, it is in our legitimate interest to use any personal data that you provide to us to ensure that we provide the relevant Services in an effective way.
Where we permit a third party to use your personal data contained within content that you submit, we will do so without your permission if we are satisfied that it is within our or the third party’s legitimate interest to use your personal data, including to promote our Services and/or services offered by the third party. If it is not within our legitimate interest, we will contact you to ask your permission, in which case our processing of such personal data will be based on your consent.
If you link to social media sites and interact with our social media pages
If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Site or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Behavioural Data and Technical Data. For more information about how we use this personal data, please see the “Website insight and analysis.” section.
The relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy notice of the relevant social media platform.
Our legal basis for processing
It is in our legitimate interest to use personal data in the ways described above to ensure that we provide the Site in an effective way and to promote our Site via social media.
II. Provision of our Services
Content creation and managing talent.
As part of our content creation services to clients, we maintain talent databases which includes Identity Data, Contact Data, Applicant Data and Publicly Available Data as well as biography and personal preferences of individuals we may use for a particular campaign. We use this information for the purpose of selecting talent for a particular campaign and working with that talent. We may obtain this information directly from the individual, via third party recruiters or agents, or publicly available sources.
As part of creating the content featuring the talent, we will process their Image Data as well as Identity and Applicant Data.
Our legal basis for processing
It is in our legitimate interests (or those of our client) to process talent personal data in this way to enable us to provide our services.
Where we process special category data in connection with this purpose that was collected from you directly, we will only do so with your explicit consent. Where we obtain this special category from publicly available sources, we will rely on the fact that the individual made such information manifestly public. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Client data insight and analysis.
We may, acting on our own behalf and on behalf of our clients, collect data about you in connection with the provision of our Services to carry out insight and analysis on an anonymised and/or aggregate basis so that we can improve our services and help our client to better understand their own customers’ interests and improve their products/ services. The data that is collected includes Behavioural Data and Technical Data, and certain Profile Data.
Our legal basis for processing
To the extent the above involves personal data, it is in our legitimate interests (or those of our client) to process personal data in this way to enable us to provide our services. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.
Please note that often such services will relate to anonymous data sets (aggregated data sets, statistical data sets and similar) and are used for high-level market analytics or understanding macro consumer habits (amongst other things). When we do this, we and our clients are not processing personal data.
Market research and focus groups
As part of our service to our clients, we may collect an individual’s data including Identity Data, Contact Data, Registration Data, Preference Data records of communications, health data (sensitive personal data), opinion data, age range, nationality, image, and education history for the purposes of carrying out market research through focus groups, interviews and user testing. We may do this on behalf of our clients or for our own purpose.
Our legal basis for processing
It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure that we provide the services requested by our clients in an effective and efficient way. Where we process special category data that was collected from an individual directly in connection with this purpose, we will only do so with the individual’s explicit consent. Where we obtain this information from publicly available sources, we will rely on the fact that the individual made such information manifestly public. Please note where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Media monitoring
As part of our service to our clients, we may monitor media sites (including social media sites) and collect information about individuals from these sites directly or using a third-party social listening provider including their opinions on how a particular client campaign was received or a client offering or on a topic that is relevant to our client more generally.
Our legal basis for processing
It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure we provide the services requested by our clients in an effective and efficient way. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Campaign reporting
As part of our service to our clients, we may collect information about individuals through third party providers or directly from the individual or through social media or other media outlets such as their contact details and opinions on how a particular client campaign was received or other feedback they may have about a campaign or a client offering.
Our legal basis for processing
It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure we provide the services requested by our clients in an effective and efficient way and provide our clients with insight into the performance of a campaign or client offering. Please note where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Surveys and voting
We may collect personal data (including Identity Data, Contact Data and Profile Data) from individuals via surveys or voting polls for the purposes of obtaining feedback on our own or our clients’ products and surveys. Participation in such polls is voluntary and individuals will have the opportunity to decide whether or not to disclose personal data. Certain personal data such as Contact Data may be required to register to vote or to take part in a survey. We would only use that information to report the results of the survey or vote.
Our legal basis for processing
It is in our legitimate interests (and those of our clients) to process personal data in this way to provide the services requested by our clients in an effective and efficient way and to understand how our clients and their products are received in the market. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Promotions
We may conduct promotions, contests or giveaways on our own behalf (or on behalf of our clients), which may require that individuals register to enter. We collect personal data from individuals in order to conduct the promotion, contest or giveaway and to deliver prizes or notices. Participation in these events and providing us with personal data is voluntary.
Our legal basis for processing
It is necessary for us to use personal data to perform our obligations in accordance with any contract that we may have (e.g. the promotion terms and conditions) or it is in our legitimate interests (and those of our clients) to process personal data in this way in order to enable individuals to participate in the promotion, contest or giveaway or we may do so in order to perform an obligation owed to individual. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Industry Mapping
We collect, and maintain data bases containing, information about journalists, talent, social media influencers, social media users and other professionals in the public relations, news or media industry collected by us or by our trusted third-party media analytics service providers. Such information may include Identity Data, Contact Data and Publicly Available Data. This information may be information that is voluntarily supplied to us by those individuals through our Site or in other situations (such as public speaking events), or information that is public or available in third party databases or via third party content platforms (including social media platforms). Further we may collect and/or review other publicly available news stories and other journalistic content including content made available through public news sites and social media sites to understand what people are saying about us and our clients. We use this information to provide our services to our clients including ensuring we and our clients are fully up to speed on public opinion in any particular area and are fully briefed when it comes to dealing with the press. We may also use this information to contact those individuals to discuss our clients’ goods and services. We may also use this information for our own internal administrative and promotional purposes.
Our legal basis for processing
It is in our legitimate interests (or those of our client) to process personal data in this way so that we can provide the services requested by our clients in an effective and efficient way. Where the personal data collected is considered special personal data, we rely on the fact that the personal data has been manifestly made public by individual in order to process their personal data. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Social media
We may collect or process individuals’ personal data (including Contact Data, Identity Data and some Profile and Publicly Available Data) who engage with us through our social media channels (including by visiting our social media pages or otherwise communicating with us via social media). We may also operate our client’s social media pages, accounts or channels acting on their behalf.
Our legal basis for processing
It is in our legitimate interests to process personal data in this way so that we can market ourselves and engage with the public. Where we carry out this activity on behalf of our clients as a data processor, we do not require a legal basis for such processing.
We will only share personal data with the third-party providers of the Social Platforms, so that we can advertise our Services whilst the individual is using those Platforms, where they have provided their consent.
Events
From time to time, we may organise and host road shows and other industry events to promote our services or on behalf of clients. For this purpose, we may process data including Identity Data and Contact Data (including email address, postal address and telephone number) to communicate with them about such events where they have specifically requested information about such events or where we have another lawful basis for sending that information to them.
If you attend one of our events, we may use your personal data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary or other requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications we send to our clients and/or publish on our Site, in print or other media.
Our legal basis for processing
It is necessary for us to use personal data in this way to perform our obligations in accordance with any contract that we may have with the individual, or it is in our or our client’s legitimate interest to use personal data in such a way to ensure that we provide our services in an effective and efficient way.
If we specifically ask your permission to use your photographs, quotes, testimonials or other content, then our processing of such personal data will be based on consent.
Where we put on events solely at the specific request of our clients we do so in our capacity as our client’s data processor and therefore do not require a legal basis to process personal data.
III. Marketing and Media Enquires
Marketing.
We may use your Identity Data, Contact Data and Marketing and Communications Data to send you (or the organisation you represent) marketing communications by email or via phone. Our marketing will include press releases and information about us.
Our legal basis for processing
We send this information and materials to you where you have consented to receive such information or materials, or where we have another lawful basis to do so to the extent required by law.
Media and informational inquiries.
We may collect personal data (including Identity Data, Contact Data and Publicly Available Data) about journalists, client contacts or industry contacts for interviews requests, for media questions, or requests for information about TBWA\Group Vietnam. We may also provide individuals with the opportunity to sign up for newsletters or to receive copies of blogs and other information that we make available. Where an individual signs up to receive such information, Contact Data may be requested in each case, together with details of other personal data that is relevant to these inquiries. This information is used in order to enable us to respond to individual requests or media requests.
Our legal basis for processing
It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure we provide the services requested by our clients in an effective and efficient way and that we provide the right information to those who request it.
B: BUSINESS ADMINISTRATION, FINANCIAL AND LEGAL
Receipt of services
If we have engaged an organisation to provide us or our client with services (for example, IT support or financial advice), we will collect and process your personal data (including Contact and Identity Data) if you are a contact within the relevant organisation in order to manage our relationship or our clients with the organization, to receive services from the organisation and, where relevant, to provide our services to others including our clients.
Our legal basis for processing
It is necessary for us to use personal data in this way to perform our obligations in accordance with any contract that we may have with the organisation, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with the organisation and are able to provide our services to others in an effective way. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Recruitment
If individuals apply for a job with us or otherwise express an interest in working for us, we will collect contact details and CV or resume information from the individual. We use such personal data for the following purposes: a) to assess the individual’s suitability for any position for which they applied (or future positions for which we think the individual may be suitable) including employment or freelancer positions, summer placements or internships and also any business support or services role whether such application has been received by us online, via email or by hard copy or in person application; b) to communicate with you in respect of the recruitment process; c) to verifying the credentials, including but not limited to verifying the authenticity of a candidate’s educational qualifications/degrees by directly contacting the relevant educational institutions or using reputable third-party verification agencies; or verifying the candidate’s employment history by contacting the provided references; d) to take any steps necessary to enter into any contract of employment (or otherwise) with the individual; e) to comply with any regulatory or legal obligations in relation to any such application; and f) in accordance with applicable legislation.
As mentioned earlier, in the event that you provide us with reference information, it is your responsibility to obtain the necessary consent from individuals whose personal data is provided to us. By providing their personal data, you agree that you are acting on their behalf and have obtained their consent for us to process their information for the specific purposes set out in this Privacy Notice.
We may operate referral programmes where some of your personal data as detailed above may be shared with us by a third party, typically a current employee. In such cases, we expressly ask the referring third party to confirm that they have your permission to share your details with us.
Our legal basis for processing
Where we use personal data in connection with recruitment and talent management it will be in connection with us entering into a legal contract with them or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment and talent management decisions for TBWA\Group Vietnam, or it is our legal obligation to use such personal data to comply with any legal obligations imposed upon us. We will not process any special data except where we are able to do so under applicable legislation or with the individual’s explicit consent.
Visiting our premises, studios or production sites
If an individual visits any of our premises, studios and/or production sites we may collect personal data including Identity or Contact Data as part of our sign in process. We may also capture their image on our surveillance camera or CCTV.
If an individual registers as a guest user for free Wi-Fi access at any of our premises, we may collect personal data including Identity and Contact Data as part of the registration process. We may also process Behavioural and Technical Data in connection with any use of this free Wi-Fi service for monitoring and record-keeping purposes, including to identify the source of service requests, optimise and maintain performance of the Wi-Fi service, and investigate and prevent system abuse.
Our legal basis for processing
It is in our legitimate interests to process personal data in this way for security reasons.
Where we process personal data in connection with providing access to our free Wi-Fi service, it is in our legitimate interests to process personal data in this way to provide the service. Where we monitor use of our free Wi-Fi service to ensure proper use of the system, we process personal data for monitoring and record-keeping purposes based on guest user consent.
Business administration, finance, and legal compliance.
We may use an individual’s personal data (including Identity Data, Contact Data, Financial Data, Transaction Data, Publicly Available Data) for the following business administration and legal compliance purposes:
Our legal basis for processing
Where we use personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we will rely on our obligation to comply with law (including any court order) to process such personal data.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with the individual’s explicit consent.
10. IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA
Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.
11. SHARING YOUR PERSONAL DATA
We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.
We are part of the Omnicom Group of marketing and PR firms and (subject to the above) may share data within Omnicom Group companies, Omnicom Networks, or with our partner agencies or government or regulatory bodies for the following purposes: (a) provide our services to clients or otherwise receive assistance in processing transactions; (b) fulfilment of requests for information, receiving and sending communications, updating marketing lists, analysing data; (c) provision of IT and other support or internal administrative business services; or (d) assistance in other ancillary to the operation of tasks, from time to time. Our agents, partners and contractors will only use your information to the extent necessary to perform their functions. For more information about the Omnicom Group, please see here: Advertising and Marketing Agencies | Omnicom Group
Further (again subject to the above) we may share your personal data with third parties, as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.
| Our clients | We may share personal data with our clients for the purposes of providing them with Services. |
| Our specialist suppliers/partners | We use various specialist suppliers and/or partners in order to provide our services including market research, event organizers, etc. |
| Third-party IT suppliers | We may share personal data with third parties who support us in providing our Site and help provide, run, and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security, and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We may also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Notice. |
| Payment providers and banks | We may share personal data with third parties who assist us with our invoicing and/or making/receiving payments. |
| Third-party post/email marketing and CRM specialists | We may share personal data with specialist suppliers who assist us in managing our marketing database and sending out email marketing communications. |
| Recruitment agencies and related organisations | We may share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies for recruitment purposes. |
| Auditors, lawyers, accountants and other professional advisers | We may share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in. |
| Law enforcement or other government and regulatory agencies and bodies | We may share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation. |
| Delivery and courier companies | We may share personal data with suppliers who assist us in the delivery of our Services to our clients. |
| Advertising partners | We may share personal data with third party advertising partners, including those within the Omnicom Group and those set out in our Cookie Privacy Notice. This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities. |
| Third-party suppliers who assist us in administering our promotions | We share personal data with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions. |
| Event partners and suppliers | When we run events, we will share your personal data with third-party service providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal data with such organisations for use in relation to the event. |
| Hotel and transport suppliers | We may share your personal data with various hotel and/or transport providers in connection with the provision of our services. |
| Production suppliers | When we work on a particular production or otherwise create content, we may share your personal data with our various production and/or content creation suppliers including without limitation production companies, artworkers, editors, creatives, post production houses, venue suppliers and/or caterers. |
| Other third parties | Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation. |
12. DATA TRANSFERS OUTSIDE VIETNAM
We may transmit personal data outside Vietnam to certain categories of third parties (as listed above in SHARING YOUR PERSONAL DATA and more specifically to Omnicom Group entities, networks or partners agencies in other locations globally.
We transfer personal data abroad in accordance with Vietnamese law.
13. OBTAINING YOUR CONSENT
Where our use of your personal data requires your consent, you can provide such consent:
Please note that if you specifically consent to additional uses of your personal data, we may use your personal data in a manner consistent with that consent.
14. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL DATA
We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Site and those who purchase our Services.
15. YOUR DATA PROTECTION RIGHTS
You have the following rights in relation to the personal data we hold about you under certain circumstances:
Data deletion does not apply where we can demonstrate that we are required to retain personal data under applicable law or other regulations.
If we have shared your personal data with others, we will let them know about the deletion where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Data subjects may exercise these rights verbally or in writing using our contact information provided in the section below entitled “how to contact us” above. We will endeavour to promptly respond to your requests. If your request is denied, we will inform you about the reasons for denial.
Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.
16. OPT OUT AND UNWANTED COMMUNICATIONS
To opt-out of any future promotional or marketing communications or any other commercial communications from us, you should send a request to us at the contact information in the section entitled “how to contact us” above.
17. THIRD PARTY LINKS AND SERVICES
This Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy Notice no longer applies to these third-party websites and third-party service providers unless we are acting as joint controllers in respect of your personal data with such third party.
You’re browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.
This Site may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.
18. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We retain personal data only for as long as is necessary for the purposes described in this Privacy Notice, and for as long as we are required to keep it by law, after which it is deleted from our systems.
The length of time for which we keep different types of personal data can vary, depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them. If any personal data is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will delete it at the end of that period. Please note that if you are an unsuccessful candidate, we may keep your information for a short period.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list so that we know not to send you further marketing communications in the future.
19. PERSONAL DATA OF MINORS
Our Site is not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal data of minors. However, due to the nature of our organisation and the Services we provide, we may from time to time collect and process personal data relating to minors. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.
20. UNINTENDED CONSEQUENCES AND DAMAGES
During the data processing, we always strive to comply with legal regulations, ensure information security, and implement system security measures to protect your personal data. However, due to technical factors or other reasons beyond our control, data loss or information leakage may occur, resulting in unintended consequences or damages for you and/or us. In such cases, we will make every effort to rectify and enhance security measures to minimize losses for you.