Privacy Policy

Privacy Policy

GENERAL PRINCIPLES

We, Fullerton health Vietnam, are committed to protecting the privacy and rights of Data Subjects in accordance with Vietnamese laws on personal data protection, including the Personal Data Protection Law No. 91/2025/QH15 effective from 1 January 2026, Decree No. 356/2025/ND-CP of the Government, and other relevant legal documents.

We process all personal data provided by you in accordance with the principles of lawfulness, transparency, purpose limitation, data minimization, confidentiality, and storage limitation, as prescribed by the Personal Data Protection Law.

This Policy describes how we collect, record, analyze, store, modify, disclose, share, delete, destroy, de-identify, and otherwise process personal data in compliance with applicable laws.

AMENDMENT TO THIS POLICY

From time to time, we may amend or update this Policy to ensure compliance with the Personal Data Protection Law and Decree No. 356/2025/ND-CP.

The updated Policy shall take effect from the date of publication and supersede all previous versions, to the extent permitted by law.

PERSONAL DATA

“Personal Data” shall be construed in accordance with Article 2 of the Personal Data Protection Law, meaning digital data or information in other forms that identifies or helps identify a specific individual, including basic personal data and sensitive personal data.

Health-related data, medical records, and medical examination or treatment results are classified as Sensitive Personal Data and shall only be processed with the explicit consent of the Data Subject, unless otherwise prescribed by law.

COLLECTION OF PERSONAL DATA

We only collect your personal data where there is a lawful basis, including:

  • The consent of the Data Subject;
  • Compliance with legal obligations;
  • Performance of relevant contracts; or
  • Other circumstances permitted under the Personal Data Protection Law.

PURPOSES OF COLLECTION, USE AND PROCESSING

We process personal data strictly for the purposes that have been notified and do not go beyond what is necessary, in accordance with the principle of data minimization under the Personal Data Protection Law.

MARKETING PURPOSES – CONSENT & WITHDRAWAL OF CONSENT

The processing of personal data for marketing purposes shall only be conducted with clear and explicit consent, which is not presumed, bundled, or misleading, in accordance with Decree No. 356/2025/ND-CP.

Data Subjects have the right to withdraw their consent at any time, and such withdrawal shall take effect from the time it is recorded in our system, within a maximum period of 30 days, unless otherwise prescribed by law.

DISCLOSURE & SHARING OF PERSONAL DATA

Personal data shall only be shared:

  • Where there is a lawful basis;
  • Where a written data processing agreement is in place with the data recipient; and
  • Within the scope necessary for the notified processing purposes,

in accordance with the Personal Data Protection Law and Decree No. 356/2025/ND-CP.

CROSS-BORDER TRANSFER OF PERSONAL DATA

Any transfer of personal data outside of Vietnam (if any) shall be conducted strictly in accordance with the conditions, procedures, and obligations relating to data protection impact assessments and record-keeping under the Personal Data Protection Law and Decree No. 356/2025/ND-CP, including cross-border data transfer impact assessments and obligations to notify or submit relevant documentation to competent authorities upon request.

RIGHTS OF DATA SUBJECTS

In accordance with the Personal Data Protection Law, you have rights in relation to your personal data, including: the right to be informed about data processing; the right to give, withhold, or withdraw consent at any time; the right to access, correct, and update data; the right to request deletion, restriction, or objection to data processing; and the right to lodge complaints, denunciations, initiate legal proceedings, and claim compensation for damages in accordance with law.

Withdrawal of Consent

The withdrawal of consent shall take effect from the time Fullerton health Vietnam receives a valid request and shall not affect the lawfulness of processing carried out prior to such withdrawal, nor processing based on other lawful grounds as prescribed by law.

Exercising Your Rights

To exercise the above rights, please contact the Personal Data Protection Officer / Department of Fullerton health Vietnam at:

Email: dpo.vietnam@fullertonhealth.com

We will receive and handle your valid request in accordance with the time limits and procedures prescribed by applicable law, depending on the nature and complexity of the request.

GOVERNING LAW

This Policy is governed by the Personal Data Protection Law No. 91/2025/QH15, Decree No. 356/2025/ND-CP, and other applicable laws of Vietnam.

Any disputes arising from this Policy shall fall under the jurisdiction of Vietnamese courts.