Welcome to CodeLink's Privacy Policy.

This policy outlines how CodeLink ("we," "us," or "our") collects, stores, and processes your personal data; and elucidates your rights concerning the collection, processing, and retention of your personal information by CodeLink in our business operations. The Privacy Policy is addressed to you as an applicant, client, supplier, business partner, consultant, visitor, interactor, or any other party for whom we may process personal data.

1. Data Controller

When CodeLink processes your personal data, CodeLink serves as the data controller. Your personal data may be shared within CodeLink only when necessary to fulfill the intended purpose. CodeLink adheres to a shared Intra Group Agreement to ensure consistent data processing procedures and maintain a uniform level of security.

2. Our Commitment to Privacy and Safeguarding Measures

We have taken measures to implement appropriate and reasonable technical and organizational security measures intended to safeguard the security of any personal information we process. Nonetheless, despite our safeguards and efforts to secure your information, we cannot guarantee that electronic transmission over the Internet or information storage technology will be 100% secure. As a result, we cannot make any promises or guarantees that hackers or cybercriminals will not be able to defeat our security and improperly collect, access, steal, or modify your information. However, we will make every effort to protect your personal information and ensure that it is secure.

3. Purposes & Methods of Collecting and Processing Personal Data

CodeLink processes personal data with specific and legitimate purposes. Some key purposes include:

Applications and recruitment
E.g. applicants applying for a job (whether solicited or non-solicited), potential candidates participating in various events (whether socially or academically), candidates contacting CodeLink with the purpose of hiring (whether as a regular employee or freelancer), entering and participating in CodeLink's recruitment process and when participating in job interviews and/or any tests.

Website visitor
When anyone performs operations/interactions on the CodeLink website, you agree that your personal information will be collected, stored, and used via cookies for our internal analytics and reporting purposes.

Form Submission
We collect personal information that you voluntarily provide to us when you register for our services, meeting schedule; or express an interest in obtaining information about us or our products; or otherwise when you contact us.

Business operations
E.g. when operating and managing the IT and communications systems, managing product and service development, buying various goods and items from suppliers, improving products and services, managing company assets, allocating company assets and human resources, strategic planning, project management, business continuity, a compilation of audit trails and other reporting tools, maintaining records relating to manufacturing and other business activities, maintaining security of premises, budgeting, financial management and reporting, communications, managing mergers, acquisitions, and reorganization or disposals.

Communication
E.g. when facilitating communication with employees, use of photographs in newsletters and other material distributed within CodeLink and to partner entities and subsidiaries, providing references, ensuring business continuity, protecting the health and safety of employees and others, safeguarding IT infrastructure, office equipment, and other property, facilitating communication in an emergency, publication of contact information and pictures on our website.

Compliance:
E.g. when monitoring compliance with internal policies or applicable laws, complying with legal and other requirements, such as income tax and national insurance deductions, recordkeeping, and reporting obligations, conducting audits, and compliance with government inspection.

4. Categories of Personal Data

CodeLink processes various categories of personal data, including but not limited to names, contact details, company name, service requirement, gender, photographs, description of current position and title, employment status, details contained in letters of application and resume/CV, previous employment background and references, education history, professional qualifications, and academic credentials, other relevant skills and test results. CodeLink does not process sensitive personal data.

5. Collection of Personal Data

Personal data may be collected directly from you, group entities, or third parties, such as references, former employers, public authorities, and online sources.

We may collect personal data from the following source(s):

1. Directly from you, such as through an application process or other forms or information you provide to CodeLink in connection with your application, partnership, consultancy work, advisory work, etc.
2. From group entities or subsidiaries, such as through an application process or other forms or information you provide to the group entity or subsidiary in connection with your employment, partnership, consultancy work, etc.
3. During your activities in the course of your application, partnership, and consultancy work, such as through your performance and interaction with other employees, customers, or other individuals
4. From third parties, which may include (the list is not exhaustive):
   a. References.
   b. Former employers.
   c. Public authorities
   d. Other third parties, including background checks, agencies, and external recruiters.
   e. Websites, LinkedIn, or similar public media.
   

6. Special Notices

CodeLink explicitly notifies the presence of video surveillance at the entries of its premises.

7. Legal Basis for Processing Personal Data

Personal data is processed based on legal grounds, including consent, contractual obligations, legal obligations, legitimate interests, and compliance with employment laws.

8. Recipients of Personal Data

CodeLink shares personal data only when necessary for processing purposes or required by law. Recipients include suppliers, business partners, third-party service providers, and public authorities. E.g. We may share your data with third-party service providers, suppliers, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The third parties we may share personal information with are as follows:

• Cloud Computing Services
• Google Cloud Platform

9. Storage

Personal data is stored only as long as necessary for processing purposes or as legally required. Storage periods vary based on the nature of the data and the processing purpose.

10. Your Rights as a Data Subject

As a data subject, you have certain rights, which are listed and further described below. CodeLink takes all necessary and adequate measures to protect your personal data and ensure your rights as a data subject.

Your rights as a data subject include the right to:

• Request access to your personal data
• Request rectification of your personal data
• Request the erasure of your personal data
• Object to the processing of your personal data and have the processing restricted

To initiate a request for reviewing, updating, or erasing your personal information, we respectfully advise you to contact CodeLink's Operations Team for assistance.

11. Withdrawal of Consent

You can withdraw your consent at any time. However, please note that withdrawing your consent to the processing of your personal information will not affect the legality of the processing that was done prior to the withdrawal. Additionally, if there are other lawful grounds for processing your personal information, your withdrawal of consent may not affect such processing. However, this will only apply if the applicable law allows for such processing.

12. Filing of Complaint

To file a complaint about CodeLink's data processing, contact CodeLink's Operation Team for resolution.

13. Contact Information

For questions or concerns, contact us at:

• Hotline: (028) 3933314
• Email: ideas@codelink.io

14. Information Collection and Management Unit

CODELINK COMPANY LIMITED Business Registration Certificate No. 0314231706 Head Office: Level 8, VINA Building, 131 Xo Viet Nghe Tinh Street, Ward 17, Binh Thanh District, Ho Chi Minh City, Vietnam

15. Changes to the Privacy Policy

This Privacy Policy will be updated on a regular basis and whenever necessary due to changes in applicable law. The Privacy Policy will always include information on the effective date of the latest version. We encourage you to check the latest version regularly for updates. The current version was approved and adopted on November 20, 2023.