Privacy Policy

Contents

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

1. 1. Introduction

   This policy is an important document. Atalink recommends that user reads it carefully.If a user has any questions regarding this privacy policy, including any requests to exercise the user’s legal rights, the user can contact Atalink using the following information:

   • Full name of legal entity: Atalink TECHNOLOGY COMPANY LIMITED
   • Email address: DPTeam@atalink.vn
   • Address: 3rd Floor, QTSC Building 1, Lot 34, Street 14, Quang Trung Software City, Tan Chanh Hiep
     Ward, District 12, HCM City, Vietnam

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

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

   In this policy, the terms are used:

   • “Atalink” in the privacy policy is Atalink TECHNOLOGY COMPANY LIMITED
   • “Personal Information” or “Personal Data” is any information relating to an identified or identifiable natural erson
   • “Identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors
   • “User” and “the user” (and other similar terms) refer to Atalink clients, individuals associated with Atalink clients, contacts, suppliers, job applicants, staff and visitors to the Atalink website http://localhost:8088

2. 2. General Information

   Atalink values the privacy of user who provide personal information to company. This privacy policy aims to give the user information on how Atalink collects and processes their personal data including any data that they may provide through Atalink website.
   People under 18 years old will not be considered as Atalink users. The access to Atalink website from them would be considered misuse of Atalink service and Atalink is not responsible for any consequence of such access.
   This policy applies to both personal information supplied to Atalink either by an individual or by legal third parties. Atalink may use personal data supplied for any of the purposes as set out in this policy, or as otherwise disclosed at the point of collection.
   In particular, Atalink will make sure that all personal data shall be processed in compliance with the following principles:

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

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

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

4. 4. What Personal Information Does Atalink Collect?

   Time limit to respond: Atalink tries to respond to all legitimate requests within one month. Occasionally it may take longer than a month to process the requests. In this case, Atalink will notify user about the processing time

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

5. 5. How Is Personal Data Collected?

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

   • Direct interactions: User may give Atalink the identity and contact data by filling in forms or providing other information via Atalink website http://localhost:8088 or email info@atalink.vn / [email_name]@atalink.vn / [email_name]@atalink.com. This includes personal data provided when:
     • Request Atalink products / services
     • Respond to a recruitment posted by Atalink on job advertisement services
     • Request marketing or providing services
     • Give Atalink some inquiries / feedback
   • Automated technologies or interactions. As user interacts with Atalink website, it may automatically collect data about the user’s equipment, browsing actions and patterns… Such technical data might reveal certain types of personal data by using cookies, server logs and other similar technologies. Please see Atalink Cookies Policy for further details
   • Third parties or publicly available sources: Atalink may receive personal data from various third parties and public sources that have legal permission to share the information. They are listed below but not limited to
     • Analytic providers [such as Google based outside the EU]. For more information on Google’s use of the personal information, please see Types of Cookies Used by Google
     • Social network sites: LinkedIn, publicly available on job board (whether by user or a legal third party)

6. 6. Legal Basis For Using Personal Data

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

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

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

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

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

7. 7. Disclosures Of Personal Data

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

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

8. 8. International Transfers

   Atalink will be entitled to disclose personal data to any third parties, and / or transferred either internally or outside of Vietnam, for the purposes as listed in the section 6 above of this policy when the consent there of has been obtained in advance.
   talink would like to make sure that personal data is stored and transferred in a way which is secure. Thus, Atalink will only transfer data to third-parties where they comply with the data protection legislation and the means of transfer safeguards.

9. 9. Data Security

   Atalink has put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, Atalink limits access to the personal data to those employees, contractors and other third parties who have a business that requires the corresponding personal data. They will only process the personal data based on an agreement with Atalink in which, among other constraints, they are subject to a duty of confidentiality.
   Atalink also has put in place procedures to deal with any suspected personal data breach and will notify user and any applicable regulator of a breach where Atalink are legally required to do so.

10. 10. Data Retention

    Atalink does not keep data longer than necessary.

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

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

11. 11.Changes To Our Privacy Policy

    This privacy policy was last updated on 06/12/2018.
    Please check back regularly to keep informed of updates to this privacy policy. Where Atalink makes significant changes to this privacy policy and has user’s email address, Atalink will send user notification of the changes.