Introduction
Chanh Xa, or chanhxa.com, as controller, (“CX”, “we”, “us”, or “our”) is committed to protecting information under our control that identifies you (“personal data”), including your name and identifying contact details. This personal data protection policy (“Policy”) serves to inform you of your rights in respect of your personal data, why we collect your personal data, how we use, share and process your personal data, and for how long we store your personal data.
General information on our processing of personal data
We collect personal data in furtherance of:
Carrying out purposes involves us providing services through and hosting our websites, applications, data analytics platforms, or other CX platforms, the conduct of surveys or elicitation of feedback, the organisation and running of events and programmes, and the administration of grants.
We will process all personal data lawfully, fairly and in a transparent manner. We will collect personal data that is adequate, relevant, and limited to what is necessary for the purposes for which they are processed. We will take reasonable steps to ensure that personal data is accurate and updated where necessary, and to erase or rectify inaccurate personal data upon request without delay.
We will not store personal data longer than is necessary for the purposes for which the personal data is processed. We will inform you of the period for which we will store your personal data but, if this is not possible, we will instead inform you of the criteria used to determine that period. We will ensure appropriate security of all personal data, including ensuring that all personal data is protected against unauthorised or unlawful processing and accidental loss, destruction, or damage, by implementing and using appropriate technical and organisational measures. We will not subject you to any decision based solely on automated processing (including profiling) which would prejudice you.
Personal data we will not collect
We will not collect personal data that reveals any of the following about you: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, or data concerning health, or sexual orientation, unless we have a legitimate interest, or have obtained your explicit consent to do so.
No requirement to provide personal data
The provision of your personal data will generally be voluntary where there is no statutory obligation to provide your personal data. Generally, we do not contractually require the provision of your personal data. However, please note that in any event, the provision of your personal data may be necessary and not providing such personal data might mean that you are not able to receive or use our services (or part thereof) or that you are disqualified from receiving certain benefits.
Sharing of personal data
Unless expressly stated otherwise in this Policy, we will only share personal data with others where you have consented to us doing so or where it is otherwise lawful for other reasons to do so, even without your consent. Where we share personal data with other persons or entities, we will ensure that all appropriate contractual arrangements and security mechanisms are in place to meet the standards under this Policy.
Your rights and how to exercise them
You have rights over your personal data, and we are committed to fulfilling these rights. You may be entitled to exercise some or all of the following rights:
(a) the right to access: (i) information regarding whether your personal data is retained; and/or (ii) a copy of all personal data relating to you which we retain, including information on the purposes of the processing, the categories of personal data concerned, the data recipients as well as potential retention periods;
(b) the right to request rectification, removal or restriction of your personal data, e.g. because: (i) it is incomplete or inaccurate; (ii) it is no longer needed for the purposes for which it was collected; or (iii) the consent on which the processing was based has since been withdrawn;
(c) the right to refuse to provide your personal data and, without impact to data processing activities that have taken place before such withdrawal, the right to withdraw your consent to the processing of your personal data at any time;
(d) the right to object, on grounds relating to your particular situation, that your personal data be subject to processing. In the event that you wish to exercise this right, please provide us with information about your particular situation. After the assessment of the information about your situation as presented by you, we will either stop processing your personal data or present you with our compelling legitimate grounds for the ongoing processing;
(e) the right to take legal action in relation to any potential breach of your rights regarding the processing of your personal data, as well as to lodge complaints before the competent data protection authority; and/or
(f) the right to require that we: (i) send to you personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format; and/or (ii) transmit such data to another controller without hindrance. Where it is technically feasible, you shall have the right to require such data to be transmitted directly from us to another controller.
To exercise these rights or to raise any complaint of our non-compliance with this Policy, please contact our support team. Please note that should you wish to exercise some or all the rights above, you must be prepared to authenticate your identity. Other grounds under which we may refuse a request is if the request is manifestly unfounded or excessive.
General information on consent
We will obtain your consent for the processing of any personal data concerning you where we are required to do so under any applicable laws. Where we seek your consent, we will inform you of the specific, and legitimate purposes for which your consent is being sought and thereafter only process the personal data for those specific, explicit, and legitimate purposes for which your consent has been obtained. Where consent is required from a child who is under the age of 18 years, we will obtain such consent from the parent or guardian instead or otherwise restrict access if consent from the parent or guardian cannot be obtained.
We will obtain such consent from you in a manner which is clearly distinguishable from other matters, and in an intelligible and easily accessible form using clear and plain language. As mentioned above, you have the right to refuse to provide or to later withdraw your consent, however, note that doing so may mean that you are not able to receive or use our services (or part thereof) or that you are disqualified from receiving certain benefits.
Specific information on the collection of personal data
If you are participating in our events, contests, surveys, or other similar programmes organised by us: For individual’s resident in the European, if you are participating in an event, programme or other similar interaction organised by us, we will collect, use and process your name and business contact information as well as other related business information, for the purposes of processing your specific request or application for a particular event or program. Your personal data will solely be processed for the fulfilment of the respective contract related to such specific event or program you are applying to.
Our Social Media Platforms: Chanh Xa owns and manages several social media pages on various platforms like Facebook, Instagram, X (formally known as Twitter), Youtube, TikTok,… We may also receive your information through content you have submitted to these social networking sites. Content submitted could be a photo you shared with us on any of the above social media platforms through participating in our activities such as tagging us in your captions in Instagram, or hash tagging #ChanhXa or #CXAgency.
If you initiate a conversation with us through the chatbot found on our Facebook page, we will receive your name automatically but seek your consent before viewing your public profile or collect any personal data. We comply with Facebook’s Terms of Service and Data Policy when collecting your personal information. The chatbot will not be used to publish any content or use data you have provided to show you advertisements. In the event where you have additional enquiries and the chatbot is unable to assist you, our social media manager will be notified and will seek your consent before collecting your contact information in order to follow-up. Content submitted through the chatbot can be deleted by contacting us.
Updates to this Policy
We reserve the right to update this Policy for reasons including but not limited to complying with relevant guidelines, regulatory directions, and other requirements of similar nature. Examples of these include future amendments to the Personal Data Protection Law. Translations of this Policy is provided only for reference and convenience to non-English readers. In case of discrepancies between the translated versions and this English version, the English version shall prevail.
Privacy Policy for Chanh Xa (Last updated : August 09, 2024)