Privacy Policy ofATLSAR COMPANY LIMITEDRegarding the Processing of Personal Data
1.1. This Privacy Policy is developed to comply with the requirements of applicable data protection laws in Vietnam and to ensure the protection of the rights and freedoms of individuals when processing their personal data, including the protection of privacy and personal and family information.
1.2. The Policy applies to all personal data processed by ATLSAR COMPANY LIMITED (hereinafter referred to as the “Operator” or “Company”).
1.3. This Policy applies to all relationships concerning the processing of personal data that arise in connection with the services provided by the Operator, both before and after the approval of this Policy.
1.4. In compliance with applicable law, this Policy is published in a freely accessible manner on our website at https://atlsar.tech.
- Personal Data: Any information related directly or indirectly to an identified or identifiable individual. In addition, our website may collect and process anonymized data (including cookies) using internet analytics services.
- User: Any visitor to our website https://atlsar.tech or user of our services.
- Personal Data Operator (Operator): A legal entity or individual who independently or jointly with others organizes and/or carries out the processing of personal data, and determines the purposes and methods of such processing.
- Processing of Personal Data: Any operation or set of operations performed on personal data, whether or not by automated means. This includes, but is not limited to:
- Collection, recording, systematization, and accumulation;
- Storage and clarification (updating or modification);
- Extraction, use, and transmission (dissemination, provision, or access);
- Anonymization, blocking, deletion, or destruction;
- De‑identification of personal data.
- The Operator has the right to:
- Determine the measures necessary to ensure compliance with applicable data protection laws.
- Delegate the processing of personal data to a third party (with appropriate contracts and, where required, the consent of the data subject).
- Continue processing personal data on legally permitted grounds even if a data subject withdraws consent, where allowed by law.
- The Operator is obliged to:
- Organize the processing of personal data in accordance with applicable laws.
- Respond to requests and inquiries from data subjects and their representatives in a timely manner.
- Provide required information to the relevant supervisory authority upon request within the prescribed time limits.
- Implement necessary technical and organizational measures to protect personal data.
- Receive clear and accessible information about the processing of their personal data.
- Request clarification, blocking, or deletion of their personal data if it is incomplete, outdated, inaccurate, or unlawfully obtained.
- Provide or withdraw consent for processing personal data for marketing or other purposes.
- Appeal to the appropriate supervisory authority or seek legal redress if they believe their rights have been violated.
1.8. Compliance with this Policy is monitored by a designated data protection officer within the Company.
1.9. Responsibility for violations of data protection requirements is determined in accordance with applicable Vietnamese law.
1.10. Users may obtain clarifications regarding the processing of their personal data by contacting the Operator at the email address provided in Section 7.
1.11. Any changes to this Privacy Policy will be reflected in this document. The current version is freely available on our website at https://atlsar.tech.
2.1. Personal data is processed solely for achieving specific, predefined, and lawful purposes. Data processing that is incompatible with these purposes is not permitted.
2.2. Only personal data necessary for achieving the stated purposes will be processed.
- Conducting its business activities, including entering into and executing contracts with partners and customers.
- Compliance with labor legislation for employment-related matters, including recruitment, career advancement, and personnel management.
- Providing users with information, updates, and personalized services (such as location-based augmented reality features) and for sending notifications regarding new products, services, or special offers. Users can opt out of marketing communications at any time.
- Analyzing and improving the quality of our website and mobile applications using aggregated and anonymized usage data.
3.1. The legal basis for processing personal data is provided by applicable data protection laws and regulatory acts in Vietnam.
- The internal regulations and charter of ATLSAR COMPANY LIMITED.
- Contracts or agreements concluded between the Operator and data subjects.
- The explicit consent of data subjects for the processing of their personal data.
4.1. The content and volume of processed personal data shall be limited to what is necessary to achieve the stated processing purposes.
- Candidates for Employment: Data such as full name, gender, citizenship, date and place of birth, contact details, education, work experience, and other information provided in resumes.
- Employees and Former Employees: Data including full name, gender, citizenship, date and place of birth, photograph, passport or identification details, addresses, contact information, and employment records.
- Family Members of Employees: Data such as full name, relationship, year of birth, and any other information required for employment-related obligations.
- Clients and Counterparties (Individuals): Data including full name, date and place of birth, passport or identification details, registration address, contact details, position held, and any other necessary information for the execution of contracts.
- Representatives of Clients and Counterparties (Legal Entities): Data such as full name, identification details, contact information, position held, and other data necessary for business relations.
4.3. The Operator may process biometric data (e.g., facial features for AR applications) in accordance with applicable law. For example, when using APIs (such as TrueDepth API on supported devices) to provide augmented reality functionalities, no data collected by such APIs leaves the user's device or is permanently stored without the user's consent.
4.4. The Operator does not process special categories of personal data (e.g., data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, or health information) unless expressly permitted by applicable law.
5.1. Personal data is processed by the Operator in accordance with applicable Vietnamese laws.
5.2. Data is processed either with the explicit consent of data subjects or on other legal grounds provided by law.
- Non-automated methods,
- Automated methods (including via electronic networks),
- A combination of both methods.
5.4. Only authorized employees whose job responsibilities include handling personal data may process such data.
- Oral or written communication,
- Direct entry into the Operator’s systems,
- Other legally permitted methods.
5.6. Disclosure or dissemination of personal data without the data subject’s consent is prohibited, except as provided by applicable law.
5.7. Transfer of personal data to investigative or law enforcement agencies, or other relevant authorities, is carried out in accordance with applicable Vietnamese law.
- Identification and mitigation of security risks;
- Adoption of internal regulations and procedures;
- Appointment of responsible personnel;
- Ensuring secure working conditions and record keeping;
- Use of secure information systems;
- Employee training in data protection.
5.9. Personal data is retained in an identifiable form only as long as necessary to achieve the purposes of processing or as required by law.
- Unauthorized processing is detected;
- The processing purpose has been achieved;
- The data retention period expires or the data subject withdraws consent (when processing is based solely on consent).
5.11. Upon achieving the processing purposes or upon withdrawal of consent (if no other legal basis exists), the Operator will terminate the processing of personal data in a timely manner, unless retention is required by law or contractual obligations.
5.12. Requests from data subjects to terminate processing will be addressed within a reasonable period, generally not exceeding 10 working days (subject to any legally permitted extension).
6.1. Upon request, the Operator will provide confirmation of the processing of personal data, including the legal grounds and purposes, within 10 working days. This period may be extended by up to 5 working days with notification to the data subject.
6.2. If a data subject identifies that their personal data is inaccurate or incomplete, the Operator will block or correct such data within 7 working days from the date of notification.
6.3. In the event of unauthorized or unlawful processing, the Operator will take immediate measures to block the processing and notify the relevant supervisory authority, as required by law.
6.4. The right of a data subject to access their personal data may be restricted if such access infringes on the rights or legitimate interests of third parties.
- Personal data will be destroyed within 30 days once the processing purpose has been fulfilled or the data is no longer required.
- If a data subject withdraws consent (where consent is the legal basis) and no other legal basis exists for retaining the data, the personal data will be destroyed within 30 days.
- Destruction of personal data is carried out by an appointed committee in accordance with the Operator’s internal regulations.
For any inquiries, clarifications, or requests regarding this Privacy Policy or the processing of your personal data, please contact:
ATLSAR COMPANY LIMITED
Floor 5, TM Building, No. 309 Bach Dang, Ward 15, Binh Thanh District, Ho Chi Minh City, Vietnam
Website: https://atlsar.tech
Email: info@atlsar.tech
Phone: +84 34 790 7040