At IE&Co, safeguarding the privacy of our customers’ information is of utmost importance to us. We strive to provide trustworthy and reliable training solutions, enabling learners to enhance their English proficiency and obtain globally recognized certifications. We adhere to the following privacy principles when managing information:
Collection of Information
IE&Co collects information directly from customers through transparent and lawful means. The information collected is based on the customer’s relationship with us. It may include name, gender, date of birth, occupation, identification documents (such as identity cards, citizen identifications, or other photo-identifying documents like fingerprints or portraits), contact details, product and service usage information, as well as information about interests, demographics, and customer-provided data. This information is collected to understand customers’ needs and ensure high-quality service.
For online customers, IE&Co may gather additional information such as IP addresses, operating systems, access times, and internet locations to track website usage, enhance the browsing experience, and recommend compatible products. Please refer to our online privacy policy for more details.
Use of Personal Information
IE&Co uses customers’ personal information solely for the purposes for which it was collected, other authorized purposes as consented by the customer, or as mandated by law. In some cases, personal information may be shared with individuals, organizations, or service providers within the public service system of the government of Vietnam, as required by law. IE&Co may also analyze customer information better to understand their needs, preferences, and interests and offer suitable products, services, and promotions. We retain personal information as long as necessary to fulfill its intended purposes or as legally required.
To ensure accuracy and effectiveness, IE&Co strives to maintain up-to-date and accurate customer records, which is essential for achieving the intended use of the information.
Protection Measures
IE&Co employs appropriate security measures to protect customers’ personal information from unauthorized access, disclosure, alteration, or misuse. We assume responsibility for the personal information in our possession, including information shared with current service providers performing duties on our behalf. When sharing personal information with these providers, they must protect it in alignment with IE&Co’s privacy policy and practices.
Privacy Statements
IE&Co is dedicated to maintaining strict control over the management of personal information. We have designated staff responsible for ensuring compliance with our privacy principles. We ensure that information regarding our privacy policy and personal information management practices is easily accessible to our customers.
Upon written request, received via mail or email, IE&Co will provide customers with reasonable access to their personal information stored in our databases, including descriptions of its use and disclosure, as required by law. Customers may also verify the accuracy and completeness of their information and request appropriate modifications or deletions, as permitted by law.
At IE&Co, we are committed to safeguarding your personal information and maintaining your trust.
Right of Access to Information
IE&Co adheres to the Data Protection Law of the Vietnamese government in all its activities, except for specific cases. Our Information Privacy and Security Policy outlines how we handle personal information, while our Cookie Policy details the cookies used on our website and their purposes.
Exercising Your Rights Regarding Personal Information Processing
You must submit a written request to us via mail or email to exercise your rights. While we encourage written requests, you can contact us by phone if you prefer face-to-face communication.
Contact Details: IE&Co. Education Joint Stock Company Room 626, 6th floor, Sannam Building, 78 Duy Tan Cau Giay, Hanoi, Vietnam Phone: +8491 134 3313 Email: iccs@ieco.edu.vn
In some cases, we may ask you to provide:
· Proof of your identity
· Proof of your home address
· Any additional information reasonably necessary to identify and process your request (e.g., details of IE&Co offices or employees you have contacted and dates of contact)
We will respond to your request only after verifying your identity.
Right to Access Personal Information
Every individual has the right to request a copy of their personal information. This means you can request the information that IE&Co holds about you. This is referred to as obtaining ‘object access’ permission.
Right to Restrict Processing of Personal Information
In some instances, you have the right to request IE&Co to restrict the processing of your personal information. IE&Co may implement restrictions by temporarily transferring the information to another processing system, making it unavailable to users, or temporarily removing published information from our website. Technical methods may also be employed to prevent further processing or alteration of personal information. When processing restrictions are in place, they will be communicated through our system.
You can request IE&Co to restrict processing in the following circumstances:
· If IE&Co is unlawfully processing your personal data, you wish to restrict its processing instead of deleting the information.
· If you suspect that the information held by IE&Co about you is incorrect. You may request a restriction until we can ascertain the accuracy of the information.
· If IE&Co no longer requires the information for the purposes for which it was collected, but you need it to establish, exercise, or defend legal claims.
· If you have objected to processing your information (see below), IE&Co needs to assess whether our legitimate interests outweigh your fundamental rights.
At IE&Co, we are committed to respecting your rights and ensuring the security and privacy of your personal information.
Processing Considered Illegal
Suppose you believe that IE&Co is processing your personal information unlawfully but do not wish for the information to be deleted. In that case, you have the right to request a restriction on the processing of that information. We will ask you to explain why you believe the processing is illegal and may request supporting evidence to substantiate your claim.
Processing of Inaccurate Personal Information
Suppose you believe that the personal information we are processing about you needs to be more accurate. In that case, you can inform IE&Co. You can request a restriction on how we use your personal information until we can verify its accuracy. We will ask you to explain why you believe the information is incorrect and may request supporting evidence regarding the alleged inaccuracy. If we determine that the personal information is incorrect, we will take appropriate steps to rectify it.
Retention of Personal Information for Legal Claims
Generally, IE&Co securely deletes or processes personal information when it is no longer required for our legitimate business purposes. However, suppose IE&Co no longer needs the personal information but it is necessary for you concerning a legal claim. In that case, you can request that we retain the information for as long as necessary. Please provide an explanation and any available supporting evidence demonstrating an ongoing or contemplated legal claim.
Right to Object to Processing
You have the right to object to the processing of your data by IE&Co in the following situations:
1. Personal Information Used for Direct Marketing: If IE&Co uses your personal information for direct marketing purposes, you have the right to object at any time. Upon exercising this right, IE&Co will cease processing your personal information for direct marketing purposes. However, we may maintain your information on an “exclusion list” to ensure that your information is not added to any marketing lists in the future.
2. Automated Decision Making and Profiling: “Profiling” refers to the automated use of personal data stored on computers to analyze or predict certain aspects that have legal effects or similarly important influences on individuals, such as economic situation, health, personal interests or preferences, and location. You have the right not to be subject to fully automated decisions (decisions made solely by electronic means without human intervention), including profiling (although you do not have a general right to object to profiling). If you are concerned that IE&Co has made a fully automated decision about you, you can raise an objection.
Please note that IE&Co is permitted to make automated decisions without human intervention if you have given explicit consent for such processing (although you retain the right to withdraw your consent). IE&Co is also allowed to make automated decisions without human intervention in the following cases:
· When automated decisions are necessary to enter into or perform a contract, or to fulfill a contract involving you and IE&Co, such as making an electronic purchase.
· When automated decisions are permitted by legislation enacted in Vietnam, with safeguards in place to protect your rights and freedoms.
Nevertheless, you still have the right to lodge a joint objection in both cases, providing reasons why you believe the processing negatively affects you. If you object, IE&Co will carefully review your reasons and consider whether to review the decision-making process in your specific case.
Right to Erasure of Personal Data (“Right to be Forgotten”)
You have the right to request that IE&Co securely delete or destroy your personal information in the following cases:
1. Personal Information No Longer Needed: If the personal information held by IE&Co about you is no longer necessary for the purposes for which it was originally collected.
2. Withdrawal of Consent: If you have previously provided consent for IE&Co to collect and process your personal information, and you notify us that you are withdrawing your consent. Please note that withdrawing your consent does not render the processing of your personal data that occurred before the withdrawal as illegal.
3. Direct Marketing: If IE&Co is processing your personal information for direct marketing purposes and you wish for us to stop.
4. Unlawful Processing: If you believe that IE&Co has unlawfully processed your personal information.
If you believe any of the above situations apply, IE&Co may ask you to explain further and provide additional information to verify your claim.
Right to Data Portability
If you have provided your information to IE&Co, you have the right to request and receive a copy in a structured, commonly used, and machine-readable format. Additionally, you can request that IE&Co transmit the information we hold about you to another organization.
Please note that there are certain situations where the right to data portability may not apply. For more detailed information, please contact us at iccs@ieco.edu.vn.
Your Right to Lodge a Complaint with the National Data Protection Regulator (Data et al.)
If you believe that IE&Co has processed your personal information unfairly or unlawfully, or if we have not complied with your rights under the GDPR, you can lodge a complaint with the national data protection regulator.
Suppose you reside in a country or territory within the European Union (EU) or European Economic Area (EEA) and believe that the concerns you have regarding your data have occurred in your country of residence. In that case, you can file a complaint with your national data protection regulator. For contact information of national data protection regulators in the EU and EEA, please refer to the European Data Protection Board website.
Please note that the initial data protection regulator you contact may not be the one directly handling your complaint. They may refer your complaint to another data protection regulator, and multiple regulators may collaborate to address your concerns. The overall management of your complaint will be handled by a “lead supervisory authority” assigned during the complaint resolution process.
If you reside outside the EU or EEA and the data protection issue you are concerned about relates to the processing of personal data in your country of residence, you may have the option to file a complaint with your national data protection or privacy regulator. You can find details of national data protection or privacy regulators in the above link. Alternatively, you may search the internet for information about your national privacy or data protection regulator.
If you have concerns regarding how we have processed your data, many data protection or privacy regulators may request that you first contact us to outline your concerns. This allows us to address the issue before you lodge a complaint or express your concerns to the regulator.
Processing of Personal Information by IE&Co
International Transfers:
IE&Co shares personal information within its broader group of entities, both within and outside the EU. We do this through a data-sharing agreement incorporating the appropriate EU model international data transfer clauses. These measures ensure the protection of your personal information, regardless of which entity within the IE&Co holds the information.
When transferring personal information outside the IE&Co to another organization, we rely on using EU model international data transfer clauses if the country where the organization is located is not deemed “adequate” by the European Commission.
Recipients:
We may engage other organizations to process your personal information on our behalf to provide services such as customer service, surveys, marketing, payment processing, fraud detection, and legal investigations. When we work with these organizations, we ensure that your personal information is protected and remains under our control.
We may also share personal information with government bodies and law enforcement agencies in certain situations. When sharing personal information with such organizations, we take reasonable measures to ensure its protection.
Marketing:
With your consent, we may use your personal information to send you direct marketing communications and better understand your preferences for products and services. This includes tailoring our marketing messages, informing you about relevant products and services, and personalizing our communications based on your interests.
The information processed for marketing purposes includes your contact details (such as name, gender, address, phone number, date of birth, and email address), information obtained from cookies and tags on your devices, information from other organizations (e.g., aggregated demographic data, publicly available sources), and details of the products and services you have purchased and used.
Based on your preferred channels, we may send marketing information through various communication channels, including phone, post, email, text, and online banner advertising. We strive to make our messages relevant by personalizing them whenever possible. We rely on legitimate business interests to inform you about our products and services, and we ensure that you consent before sending marketing messages. Each message you receive also provides an option to opt-out.
We will only promote products and services from other organizations if you permit us. You can request us to stop sending you marketing information or withdraw your consent at any time.
Retention:
IE&Co retains personal information following our corporate retention requirements. Further details about our corporate retention schedule can be obtained by contacting us at iccs@ieco.edu.vn.
Fraud Checks
IE&Co conducts fraud checks on all customers as we must fulfil our contractual services and ensure that payments are made appropriately. These checks also serve to protect individuals from fraudulent transactions. In cases where we suspect fraudulent activity, we may block the purchase of a product.
Given the high volume of transactions, we utilize automated systems, including third-party systems, for fraud detection purposes. These systems analyze each sale and make automated decisions regarding whether to accept or decline a transaction. This approach is fairer, more accurate, and more efficient than human checks, considering the timeframes and the number of customers we deal with.
The checks and decisions consider various components, including industry indicators of fraud provided by our expert fraud detection provider and fraud patterns identified on our platforms. These factors collectively generate an automated score indicating the likelihood of a fraudulent transaction. If our systems assign a high score to a customer, we may decline the order or restrict access to our services. The specific fraud indicators are dynamic and change based on the types of fraud detected globally, within the country, and on our platforms at any given time.
You have certain rights concerning this activity. Our fraud detection measures are implemented to safeguard all our customers, as well as IE&Co. If you wish to contest a fraud decision made about you or require further information about such a decision, you can exercise your rights by contacting us at: iccs@ieco.edu.vn.
General Data Protection Queries
If you would like to communicate with us regarding this privacy notice or any issues related to information governance or data protection, please contact IE&Co’s Data Protection Officer via email address iccs@ieco.edu.vn.