FPT Software Company, Ltd. ("FPT Software" hereinafter) Corporate Data Protection Policy, privacy statement, procedures, guidelines, and templates lay out strict requirements for processing personal data pertaining to customers, business partners, employees or any other individual. It meets the requirements of the European Data Protection Regulation/Directive, PDPD356 VN, PDPL91 VN as well as other national Data Protection Regulations and ensures compliance with the principles of national and international data protection laws in force all over the world. The policy, privacy statement, procedures, guidelines, and templates set a globally applicable data protection and security standard for FPT Software and regulates the sharing of information between FPT Software, subsidiaries, legal entities, and partners. FPT Software have established guiding data protection principles – among them transparency, data economy and data security – as FPT Software guidelines.  

The FPT Software Personal Data Handbook including the Protection Policy, Policy_Personal Data Protection Management_v3.7 and Policy_Cookie_Statement_v1.0 and privacy statement applies worldwide to FPT Software, Subsidiaries as well legal entities and is based on globally accepted, basic principles on data protection. Ensuring data protection is the foundation of trustworthy business relationships and the reputation of the FPT Software as a first-class employer.  

The Data Protection Policy provides one of the necessary framework conditions for cross-border data transfer among FPT Software, Subsidiaries, and legal entities. It ensures the adequate level of data protection prescribed by the European Union General Data Protection Regulation, APPI, PDPA, PDPD356 VN, PDPL91 VN or other national Personal Data Protection Regulations and the national laws for cross-border data transmission, including in countries that do not yet have adequate data protection laws. 

To standardize the collection, processing, transfer, and use of personal data, and promote the reasonable, lawfully, fairly, and transparent use of personal data to prevent personal data from being stolen, altered, damaged, lost or leaked, FPT Software establishes the personal data protection management policy, Data Protection Handbook, Cookie Statement, and information security policies.

Cookies used on fptsoftware.com 

The Data Protection Policy, privacy statement, procedures, guidelines, and templates comprise the internationally accepted data privacy principles without replacing the existing national/international laws. It supplements the national data privacy laws. The relevant national law will take precedence in the event that it conflicts with the Data Protection Policy and guidelines, or it has stricter requirements than this Policy and guidelines. The content of the Data Protection Policy, procedures and guidelines must also be observed in the absence of corresponding national legislation. The reporting requirements for data processing under national laws must be observed. 

Each subsidiary or legal entity of FPT Software is responsible for compliance with the Data Protection Policy, this privacy statement, guidelines, and the legal obligations. If there is reason to believe that legal obligations contradict the duties under the Data Protection Policy, privacy statement, procedures or the guidelines, the relevant subsidiary or legal entity must inform the Global Data Protection Officer. In the event of conflicts between national legislation, the Data Protection Policy, and this privacy statement, FPT Software will work with the relevant subsidiary or legal entity of FPT Software to find a practical solution that meets the purpose of the Data Protection Policy, guidelines, and this procedure. 

The Global Data Protection Officer is responsible for ensuring that the privacy statement is correct and that mechanisms exist such as having the privacy statement on FPT Software website to make all data subjects aware of the contents of this notice prior FPT Software commencing collection of their data. 

The Global Data Protection Officer is responsible for ensuring that this statement is made available to data subjects prior to FPT Software collecting/processing their personal data.

All Employees/Staff of FPT Software who interact with data subjects are responsible for ensuring that this statement is drawn to the data subject’s attention and their consent to the processing of their data is secured.

FPT Software is part of FPT Corporation (FPT – HoSE) – the global leading technology and IT services group headquartered in Vietnam with nearly US$1.2 billion in revenue and 40,000 employees. Qualified with CMMI Level 5 & ISO 27001:2022, ISO 27701:2019, ASPICE LEVEL 3, FPT Software delivers world-class services in Smart factory, Digital platform, RPA, AI, IoT, Enterprise Mobilization, Cloud, AR/VR, Embedded System, Managed service, Testing, Platform modernization, Business Applications, Application Service, BPO and more services globally from delivery centers across the United States, Japan, Europe, Australia, Vietnam and the Asia Pacific.

You can assess or visit our website at any time without informing us who you are or providing us any personal information. However, we may collect information at our websites in two ways: (1) directly (for example, when you provide information, such as your name, email address, designation, company, country and telephone number, to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our website’s technology, we may collect certain information such as your IP address, demographics, your computers’ operating system, and browser type in case you give us consent for these information).

We do not attempt to track your personal information in order to identify you, but gathering these contact information in order to make up the web traffic routing, to diagnose problems with server for administration of our website, to better understand how you interact with our website and services and to re-design and upgrade the website for better use. If you choose not to provide your personal information that is mandatory to process your request, we may not be able to provide the corresponding service.

We use personal data to provide you with information you request, process online job applications, and for other purposes which we would describe to you at the point where it is collected or which will be obvious to you. For example:

• To further fulfil your requirements on products and services
• To contact you with the aim of developing a business relationship
• To feedback to your idea and/or to provide you relevant information at your requirements
• To contact you for marketing purpose such as customer surveys
• To inform you about our company
• To obey regulations in applicable laws

By consenting to this Cookie Statement, you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for FPT Software to process personal data, but it must be explicitly given. Where we are asking you for personal data, we will always tell you why and how the information will be used. 

Means: FPT Software will inform you about the purpose of the processing, contact details of the Data controller or its representative, lawful basis of the processing, personal data was obtained, if not obtained directly from the data subject.

FPT Software provide updated information without any undue delay and before continuing with the processing if the purposes for the processing of the personal data are changed or extended. In this case FPT Software will ask for a new consent.

You may withdraw consent at any time by email, a written letter or telephone call to our Global Data Protection Officer or local subsidiary in line with our Procedure Withdrawal of Consent (Procedure_Consent Withdrawal_V1.6). Retrieve a copy of guideline and procedure Global Data Protection Officer, published on fptsoftware.com).

We do not share your personal information with third parties without seeking your prior permission, except as otherwise permitted or required under applicable law. We will seek your consent prior to using or sharing personal information for any purpose beyond the requirement for which it was originally collected. However, we may share your personal information within FPT Software or with any of its subsidiaries, business partners, service vendors, authorized third-party agents, or contractors located in any part of the world for the purposes of data processing, storage, or to provide a requested service or transaction, after ensuring that such entities are contractually bound by data privacy obligations. When required, we may disclose personal information to external law enforcement bodies or regulatory authorities, in order to comply with legal obligations to support our marketing effectiveness, FPT Software integrates with the LinkedIn Conversion API, allowing us to analyze opportunities and improve campaign performance. In this context, certain pseudonymized personal data (e.g., hashed email) may be shared with LinkedIn Corporation. Data is transferred securely and processed solely for conversion tracking and analytics. We maintain full compliance with data protection laws and uphold all data subject rights.

We do not intend for our websites or online services to be used by anyone under the age of 13. If you are a parent or guardian and believe we may have collected information about a child, please contact us as described in this Cookie Statement. 

FPT Software considers that, as a general rule, a child of 16 and over is mature enough to understand giving of consent, they are giving and should be in a position to give that consent. All Data subjects will be required to verify their identity. Where personal data is sought in respect of a child below the age of 16, a parent or guardian must give the consent on behalf of the child. Any response will be directed to the parent or guardian. FPT Software will need to be satisfied as to the identity of the parent or guardian, and that they are acting in the best interests of the child, before excepting the consent in respect of the child. Parent or guardian has the obligation to explain the process and the content to the child and if it is legally required (PDPD356 VN, PDPL91 VN) to get the consent of a child, it is parent, agent or guardian responsibility. 

If parent applying on behalf of a child under 16 years of age, FPT Software will require proof of identity and address of parent and that of the child, together with the birth certificate of the child.
If a legal guardian applying on behalf of a child under 16 years of age, FPT Software will require proof of guardian identity and address and that of the data subject, together with proof of authority to act as legal guardian and the birth certificate of the child.

If you are an agent acting on someone’s behalf (e.g. a solicitor applying on behalf of a client), FPT Software may require proof of agent identity and address and that of the data subject, and proof that the data subject has given consent to act on their behalf.

FPT Software will pass on your personal data to third parties.

FPT Software will process personal data for one year. Retention period 2 years or based on applicable national laws/regulations (reference: Guideline_Personal Data Retention_v3.7, Procedure_Retention of Records_v1.6. Retrieve a copy of guideline and procedure Global Data Protection Officer, published on fptsoftware.com). 

FPT Software understand that your privacy is important to you and is committed to being transparent about the technologies it uses. This Cookie Policy explains how and why cookies may be stored on and accessed from your device when you use or visit any website or app that posts a link to this Policy. Please read this Cookie Policy carefully before using our Site. This Cookie Policy should be read together with our Data Protection Policy ‘Policy_Personal Data Protection Management’ and our Terms of Use.

When you visit our website fptsoftware.com, we will collect additional website usage data. Cookies are small text files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.

Cookies are very useful and enable an internet site to recognize you, log when you visit a particular page, provide a secure connection to a website and enhance your user experience by: improving your browsing comfort, and/ or adapting the content of a page to your areas of interest.

We may use information collected from our cookies to identify user behavior and to serve content and offers based on your profile, and for the other purposes described below, to the extent legally permissible in certain jurisdictions. In addition, when you visit our websites, our advertisement partners, whom we have engaged for re-marketing, may introduce cookies. Based on your browsing of our website you may see our advertisements while browsing through our advertisement partner websites and/or their network websites.

Such cookies would allow us to monitor the effectiveness of the advertisements and to make the advertisements more relevant to you.

• Strictly Necessary: Essential for the website to function, such as accessing secure areas. 
  
• Functional: Remember choices made by the user, like language or region. 
  
• Performance/Analytics: Collect data on how visitors use a website, like which pages are visited most. 
  
• Targeting/Advertising: Deliver relevant ads and track ad campaign performance  
  

This site contains links to other websites, but they are neither FPT Software’s websites nor under control of FPT Software. FPT Software is not responsible for the privacy practices or the content and transactions of such websites. You are required to read carefully the Privacy/Cookie part of those linked websites to assure that you have fully understood the way of personal information collection and sharing before providing your own information. You shall take all responsibility of risk that may incur when using those websites. 

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right to be informed – you have the right to request information what kind of your personal data are collect, use, processed, for what purpose, from which source, lawful basis of processing 
• Right of access – you have the right to request a copy of the information that we hold about you. 
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten/erasure – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to Object: Individuals can object to the processing of their personal data in certain circumstances.
• Rights related to Automated Decision Making: Individuals have rights concerning decisions made by automated means that significantly affect them
  According to PDPL91, data subjects has further below rights:
• The right to consent or refuse, and to withdraw consent for personal data processing;
• The right to file complaints, denunciations, lawsuits, and claim compensation as prescribed by law;
• The right to request competent authorities or related entities to implement measures to protect their personal data according to legal regulations 

All the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

FPT Software  accepts the following forms of ID when information on your personal data or data subject rights are requested:

Passport, driving licence, ID card

If you wish to make a complaint about how your personal data is being processed by FPT Software or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and FPT Software’s data protection representatives Global Data Protection Officer.

Contact details of other countries supervisory authorities you can get form DPO at any time without any undue delay.

FPT Software reserves the rights to change, modify, add or remove in whole or in part this Privacy Statement at its sole discretion, at any time. Therefore, you are responsible for regularly reviewing this statement. Changes of this Privacy Statements will be posted on this website. These changes will also be effective when they are posted. Your continued use of this statement constitutes your agreement to all such terms.

If you have any questions about our Cookie Statement or about how to protect your personal information, you can contact the Global Data Protection Officer of FPT Software or every local subsidiary of FPT Software. 
Global Data Protection Officer: Michael Hering, [email protected], +84 902606236,
F-Town Building 3, Lot E3, Vo Chi Cong Street, High-tech Park, Tang Nhon Phu Ward, Ho Chi Minh City, Vietnam

The Data Protection Officer (GDPO) is the owner of this document and is responsible for ensuring that this statement is reviewed in line with the review requirements of the GDPR and Guideline_Personal Data Protection Policy Development_v2.7.

This statement was approved by the COO, board member responsible for data protection, see record of change. 

See Guideline_Framework Personal Data Protection Handbook_v1.2
Guideline_Relevant Data Protection Law Regulation Standard_v1.2. (see Data Protection Policy published on our website).