The Ho Chi Minh City Economic Forum (hereafter the “Forum”, “we”, “us” or “our”) is committed to complying with the Applicable Data Protection Law and to the protection and confidentiality of the personal data of Participants, Partners and Community Members (hereinafter also referred to as “User”, “you” or “your”).

In this Privacy Notice (the “Notice”), we explain how we collect, share and use personal data we obtain from you when you register, access or use our HEF platform (“HEF”) including to register for and participate in meetings, activities, workshops, videoconferences and other physical and virtual events organized or co-organized by the Forum (the “Events”), communicate and interact with us in connection with Events, and how you can exercise your data protection rights.

The Forum wants you to be well informed of the collection, processing, use and sharing of your personal data in connection with HEF and the activities that are facilitated via HEF, as well as when registering to, and attending the Events. Please read this Notice carefully prior to entering your personal data and using HEF.

Definitions

• Applicable Data Protection Law: (i) the Regulation of Vietnam on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing and (ii) any applicable national data protection laws or regulations, as amended from time to time;
• Communities Members: Members of the Forum Communities;
• Concepts such as “controller”, “processor”, “data subject”, “personal data”, “data breach”, and “processing” (and “process”) shall have the meanings given to them in the Applicable Data Protection Law;
• Forum Community(ies) or Community(ies): Global network(s) of selected individuals from academia, business, government, international organizations and civil society with the aspiration to shape the global, regional and industry agendas;
• Forum Entities: The Forum, its affiliates, subsidiaries or offices, including The Ho Chi Minh City Economic Forum, Viet Nam Center for the Fourth Industrial Revolution (Ho Chi Minh city), as well as the Forum’s affiliated organizations;
• Participants: Any natural person registered or participating in an Event;
• Partners: Any legal person that has obtained the partnership or membership-status with the Forum;
• Strategic Partners: a selected group of Partners who provide essential leadership in support of the Forum’s mission.

Identification of the controller and contact details

The Ho Chi Minh City Economic Forum, with registered offices at HCMC Hi-Tech Park – Lot E1, Hanoi Highway, Tang Nhon Phu Ward, Ho Chi Minh City, Vietnam, is the controller of the processing under this Notice, unless otherwise stated. If you have any questions or concerns about our use of your personal data or want to exercise your data protection rights, you can contact us at contact@hef.gov.vn

What types of personal data do we collect?

The Forum may collect and process the following types of personal data about you:

• Information that you provide voluntarily, which may include:
  • Identification details (including your name, first name, date of birth, gender, nationality, company or affiliation and title);
  • Contact details (including email address, postal address, telephone number);
  • Voice, image and video recording (including your name, appearance, voice, as well as your performance and presentation);
  • Written comments, chats and questions asked online during virtual Events;
  • Files and screen that you may share with other Participants during virtual Events;
  • Biographical material;
  • IDs and passports and the information they contain;
  • Financial details (e.g. your invoice and payment information);
  • Limited sensitive personal data (e.g. COVID-19 certificates and negative COVID-19 test results and the information they contain).
• Information that we collect automatically

When you visit HEF, we may collect certain information automatically from your device. In some countries, including in Vietnam, this information may be considered personal data under the Applicable Data Protection Law.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, preferences, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with HEF, including the pages accessed and links clicked.

• Information that we obtain indirectly from third parties

From time to time, we may collect some of the personal data listed above indirectly (e.g. by accessing publicly available information such as your name, title, organisation and contact details on the Internet or social media (finding your latest position on LinkedIn) or by accessing your company’s information on publicly available company registers or corporate websites). In some cases, we may obtain personal data about you from third parties, such as you spouse, family members, or colleagues at your company or organization. If you are tested for COVID-19 at an in-person Event and the testing process is organized by us, the relevant testing laboratory will share your negative test results (including the validity period) with us and our security and access partner for verification purposes and to manage access to the Event via badges. If your test is positive, the testing laboratory may, with your consent, share this result with us so that we can provide you with appropriate support and assistance.

How do we use your data and for what purposes?

The Forum processes your personal data for the following purposes:

• To enable you to travel and participate in our physical Events, to organise sessions and meetings during these Events and to provide you with any other services in connection with your participation at these Events;
• To verify your COVID-19 certificates and negative COVID-19 test results (including their validity period) for health and safety purposes, to control and manage access to in-person Events via badges, and to provide you with other support services related thereto;
• To assist and support you in the event of a positive COVID-19 test result before or during a physical Event, if you so wish;
• To record virtual Events in order to make them accessible to Participants and a broader public;
• To manage your HEF account (including your registration) and to allow you to access HEF applications and features (such as blogs, Forum Community & project pages, messaging and member areas);
• To analyse and monitor general trends and patterns on the use of HEF (we use pseudonymized or anonymized data for this purpose to the extent possible);
• To improve the content, performance and organization of HEF;
• To promote the Forum’s image and activities in Event reports, on our website and via social media to a broader public;
• To manage the Forum’s public communications and relations;
• To communicate with you for direct marketing purposes, including to send you emails regarding Events, newsletters related to the Forum and/or Forum Community activities and generally to promote the Forum’s activities;
• To invite you to our future Events;
• To respond to your questions or queries and exercise of your data protection rights;
• To share general profile information and lists of Participants who are attending Events with other registered Participants and prospective Participants who may attend our Events;
• To enable peer-to-peer interactions at Events, sessions and workshops;
• To facilitate Community and/or platform engagement (we may share your general profile information which may include your contact details);
• To conduct surveys in connection with the Events, Community and/or platform engagements;
• To conduct internal data analytics and statistics on a non-identifiable basis.

For other legitimate interests of ours such as planning and managing security and logistics at Events, to manage access to our Events via badges and the security badge system and generally to maintain security at all times during our Events;

We will use the personal data we collect from you only for the purposes described in this Notice or for purposes that we explain to you at the time we collect your personal data.  However, we may also use your personal data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) in accordance with the Applicable Data Protection Law. We may also process your personal data to comply with laws, directives and recommendations from authorities and internal regulations (“compliance”) and as part of our corporate governance, including business organization and development.

On what legal grounds do we process your personal data?

We will process your personal data in order to manage our relationship with you and to execute the Terms of Use of HEF that you have agreed to.

We may also be required to process your personal data to comply with local laws and regulations, for example where we are required to disclose certain information to the local authorities within the countries, in which we are organizing our Events.

Otherwise, we will process your personal data to carry out our legitimate business interests, where such interests do not override your fundamental rights and liberties. For example, the Forum has a legitimate business interest to promote and advertise the participation of some well-known public figures attending our Events on our website and on social media, as well as for public relation purposes.

In the case of providing your consent for certain processing activities (for direct marketing purposes and for the processing of your sensitive personal data in accordance with the Applicable Data Protection Law, e.g. a positive COVID-19 test result), we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us written notice by mail or via HEF, as applicable. In relation to your consent given in the context of COVID-19 health and safety measures implemented by us for a particular in-person Event, you can withdraw consent at any time by sending us an email at contact@hef.gov.vn. Once we have received notification of your withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.

Where the provision of personal data is based on a statutory or contractual requirement, or a requirement necessary to commit to a contract, you are obliged to provide us with this personal data. If you refuse or do not allow us to process your personal data, you will not be able to benefit from all the services offered by the Forum. For example, we may not be able to complete your registration to an Event or give you full access to our Participants’ list.

Who do we share your data with?

The Forum may share your personal data with the following parties:

Forum Entities

The Forum may share your personal data with the Forum Entities in other locations around the world, for example, to manage and notify you about our Events, to collaborate between Forum Entities in furtherance of the Forum’s mission, or to answer your questions adequately.

Other Participants of the Forum Events and Community Members

The Forum makes available an interactive Participant list to all Participants who are attending an Event and to Community Members who may then process the personal data for their own purposes as independent controllers. The interactive list of Participants is available to all Participants via a dedicated tab on their HEF profile. Each Participant may opt-in via his/her HEF profile to decide whether he/she wants to make his/her contact details accessible to other Participants via HEF.

The Forum also shares information about the sessions organized at its Events with its Participants. This may include, for example, the name and title of speakers, moderators and other session Participants, as well as the names of attendees for each session.

Information about Community Members (name, position, organisation and contact details) may be shared within the Forum Community for the purposes of personal communication and dialogue in furtherance of the Forum Community’s activities.

Strategic Partners

The Forum may also share the email addresses of its Participants at a given Event with its Strategic Partners. In such case, we will ask our Participants to give their consent before sharing their email addresses with our Strategic Partners via their HEF profiles.

Third party service providers

The Forum shares your personal data with third party service providers (e.g. to host your data, to manage access to Events via badges, for security purposes and to provide any other support services to the Forum. For example, the Forum shares your personal data with PublicisLive as our official provider for logistics and key support services for our Events. The Forum will ensure that any third parties who are given access to your personal data are only permitted to process the personal data for the purposes set out in this Notice and in accordance with the instructions provided by the Forum.

COVID-19 test provider and testing laboratory

To the extent that participation in an in-person Event requires Participants to be tested for COVID-19 and that this testing process is organized by the Forum, the Forum will share limited personal data about you (i.e. full name, date of birth and email address) with our test provider and testing laboratory so that they can perform these tests, notify you of your results, and issue you a valid COVID-19 test certificate, if your test is negative.

Public authorities

The Forum may share your personal data with local authorities to the extent deemed necessary by the Forum for the purposes set forth in this Notice, in particular for security reasons, or as required by mandatory applicable local laws and regulations, including COVID-19 health regulations.

Other third parties

The Forum may also share your personal data with other third parties in accordance with the Applicable Data Protection Law, such as universities or partnering organizations and institutions to co-organize events, platform activities that foster public-private collaboration, as well as other third parties that may require certain of your personal data for operational reasons.

Processing by Participants, Strategic Partners, Community Members and other third parties for their own activities

The Participants, Community Members, Strategic Partners and other third parties (such as universities, local authorities, test providers and testing laboratory) may process some of your personal data (such as name, position, organisation, contact details and COVID-19 test results) for their own purposes as independent controllers. The Forum is not responsible for any processing of your personal data by these parties in their capacity as controller. For more information about the processing activities carried out by these parties, please read their terms and conditions , as well as privacy notices.

How we protect your privacy

We will process personal data in accordance with this Notice, as follows:

• Fairness: We will process your personal data fairly. This means that we are transparent about our use of your personal data and its accordance with the Applicable Data Protection Law;
• Purpose limitation: We will process your personal data for specified and lawful purposes and will not process it in a manner that is incompatible with those purposes;
• Data minimization: We only collect personal data that is adequate, relevant and limited to what is necessary in relation to the purposes mentioned above;
• Data accuracy: We take appropriate measures to ensure that personal data that we hold about you is accurate, complete and, where necessary, kept up to date. However, it is also your responsibility to ensure that your personal data is kept as accurate, complete and current as possible by informing the Forum promptly of any changes or errors. You should notify us of any changes to the personal data that we have on file (e.g. a change of address);
• Data security: We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data. Specifically, any personal data provided to the Forum by Users of HEF is handled with due care and security and will not be used in ways other than as set forth in this Notice, or in any site/area-specific policies, or in ways that are not compliant with the Applicable Data Protection Law. Furthermore, the Forum employs a range of technologies and security measures to protect the personal data maintained on Forum systems from loss, misuse, unauthorized access or disclosure, alteration or destruction. Finally, all Forum employees who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of all such personal data.

International data transfers

The Forum operates at a global level and, as a result, your personal data may be transferred to, and processed in, countries other than the country in which you are resident. In some cases, these countries may be located outside Vietnam which therefore may have data protection laws that are different from the laws of your country of residence.

We may also disclose personal data to agencies, courts and other authorities in Vietnam and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests.

How long do we keep your personal data?

The Forum will retain your personal data for as long as our processing purposes, legal retention periods and our legitimate interests in documenting and preserving evidence require it or storage is a technical requirement. If there are no contrary legal or contractual obligations, we will delete or anonymize your personal data once the storage or processing period has expired as part of our usual processes. For example, we may retain personal data we obtain from you for as long as we have an ongoing legitimate business need to do so (e.g. to manage our relationship with you, to provide you with service(s) you have requested or to comply with applicable legal, tax or accounting requirements).

In the case of IDs and passports, we will delete or anonymize the personal data as soon as the processing is no longer necessary for the purpose for which the personal data are being used.

Concerning HEF messaging content (e.g. messages, attachments), we will delete messages older than 24-month period.

Regarding COVID-19 certificate and COVID-19 test results that we process in the context of an in-person Event, we will delete this information three months after the end of the Event.

Even if initial transmission of personal data to the Forum is not immediately followed by your registration for a Forum meeting, the Forum may nonetheless store such personal data for a reasonable time period in order to have access to such data for a possible future registration, whether as a result of your own initiative, the initiative of your employer, another accompanying person or spouse, or the initiative of the Forum. We may also use this data to conduct internal data analytics.

Your data protection rights

In accordance with the Applicable Data Protection Law, you have the following data protection rights:

• You may request access to and obtain a copy of your personal data.
• You may also request that any personal data that is inaccurate or incomplete be rectified or completed.
• You may request that your personal data be erased in accordance with the Applicable Data Protection Law (for example, where the personal data is no longer needed to achieve the purposes for which the information was initially collected);
• In addition, you may object to the processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data in accordance with Applicable Data Protection Law.
• You have the right to opt-out of electronic marketing communications we send you at any time and free of charge. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided at the beginning of this Notice.
• If we have collected and are processing your personal data based on your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

Please note that conditions, exceptions or restrictions apply to these rights under Applicable Data Protection Law (for example to protect third parties). We will inform you accordingly where applicable.

You may exercise any of the rights above at any time in accordance with the Applicable Data Protection Law by contacting us via the contact details provided at the beginning of this Notice. We will respond to your request in accordance with the Applicable Data Protection Law.

Minors

The services we provide on the HEF platform are not intended for individuals below the age of 18. If you are under 18, please do not attempt to register or to provide your personal data on HEF.

Linking to other websites

The HEF platform may include links to other websites that are not operated or maintained by the Forum and are not covered by this Notice. The processing of personal data on these third-party websites, including the use of cookies, is subject to these third parties’ notices and terms and conditions. Please review the notices and terms and conditions of each website you visit.

We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.

Updates to this Policy

We may update this Notice from time to time in response to changing legal, technical or business developments. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Notice changes if and where this is required by the Applicable Data Protection Law.

You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this Notice.