Skylight Consulting Vietnam Co., Ltd. (hereinafter referred to as “Skylight”), being highly aware of the significance of protecting personal information, hereby sets forth the Privacy Policy as described below, with the orientation that this Privacy Policy will become the principle and standard applied to all Skylight’s officers and employees and to any and all personal information that Skylight may acquire in the course of conducting its business.

By making a relationship with Skylight (using Skylight’s services and/or cooperating to carry out business activities with Skylight and/or entering into an employment contract or other contract/agreement with Skylight), you agree to the terms of this Privacy Policy.

  1. Personal information
    1. Definition
      Personal information is information which personally identifies an individual, such as name, email address, phone number or billing information, or other data that can be reasonably linked to such information by Skylight.
    2. Method of collecting personal information:
      • Directly collect information created or provided by the individuals/organizations holding that data when making and maintaining a relationship with Skylight.
      • Collect information related to the activity of the individuals/organizations in relationship with Skylight (such as information about the activity in Skylight’ services; the apps, browsers, and devices used to access Skylight’ services; the location when using Skylight’ services; …)
      • Collect information from publicly accessible sources.
      • Several other methods of data collection are not contrary to the provisions of the law.
  2. Basic Principle on Acquisition, Use, Provision, etc. of Personal Information
    1. Principle for acquiring personal information directly
      • Skylight will acquire personal information in a lawful and fair manner by obtaining the direct consent of the person holding such personal information.
      • When acquiring the personal information on its customers, employees, job candidates, etc., Skylight will clarify the intended use of such personal information, for example: to provide, maintain, improve Skylight’ services; provide personalized services; communicate; protect Skylight, customers, employees, job candidates, and the public. Skylight will not seek to acquire any sensitive information that is likely to infringe upon the interests of any individual person unless the express consent of said individual person is in place or acquisition of such information is  allowed by the relevant laws, ordinances, etc.
    2. Principle for using and providing personal information
      • Except where circumstances otherwise require,  Skylight will take measures and actions to ensure that any and all information obtained by Skylight is only used within the boundaries necessary for the achievement of intended use or disclosed to any third party.
      • If Skylight entrusts any third party to handle any information obtained by it, Skylight will base on instructions and in accordance with our Privacy Policy and will conduct a strict examination of, enter into a confidentiality agreement with, and conduct proper supervision of such entrusted third-party.
      • Skylight will not share personal information outside without prior consent of the person holding such personal information, unless Skylight find that accessing, using, maintaining or disclosing such information is reasonably and necessary to:
        • Fulfill the own request of the person holding such personal information.
        • Comply with any applicable law, regulation, legal process or enforceable governmental request. 
        • Enforce applicable Terms of Service, including investigating possible violations.
        • Detect, prevent, or address fraud, security, or technical problems.
        • Protect against damage to the rights, property, or safety of Skylight and/or the public in general as required by law or permitted by law.
      • Skylight may share non-personally identifiable information publicly and with our partners — such as publishers, advertisers, developers, or rights holders.
      • If Skylight is involved in a merger, acquisition, or asset sale, Skylight will continue to ensure the confidentiality of all personal information and notify affected users before personal information is disclosed. transferred or subject to a different privacy policy.
    3. Compliance with Laws, Ordinances, and Internal Regulations
      Skylight will comply with the Act on the Protection of Personal Information, other relevant laws and ordinances in Vietnam and will handle personal information pursuant to its internal regulations. Internal regulations must not contravene the provisions of law. In case of conflict between internal regulations and legal regulations, the law shall prevail.
    4. Proper Method for Managing Personal Information
      Skylight will keep any and all personal information acquired by it in an accurate and latest state and will take actions necessary and appropriate for prevention of or remedy from divulgation, loss or damage of personal information, or otherwise necessary and appropriate for the safe management of personal information., including but not limited to:
      • Skylight will use encryption to keep personal information as data secure during transmission. Storage of these data will be done in accordance with the provisions of the Cybersecurity Law.
      • Skylight will review the ways Skylight use, store and collect information, including physical security measures, to prevent unauthorized access to our systems.
      • Skylight make sure anyone with access to personal information is required to fulfill strict confidentiality obligations in their contract and may be subject to disciplinary action or termination if they fail to comply with those obligations.
      • Skylight will regularly check this Privacy Policy and ensure that Skylight handle all personal information in a manner that complies with this policy.
    5. Continuous Improvement in the Protection of Personal Information
      Skylight will endeavor to attain continuous improvement in the protection of personal information by further perfecting the steps of collect, use and disclose information. Besides, Skylight will make effort to apply the most advanced technical and security measures to prevent and remedy problems that occur in the process of protecting personal information.
    6. Privacy controls
      The data holder has a lawful right to use the data in accordance with this Privacy Policy and relevant laws.
      • Reviewing, and updating information: a person can always review and update his/her personal information.
      • Exporting information: a person can export and/or request Skylight to provide a copy of personal information of that person acquired by Skylight.
      • Deleting your information: a person can delete and/or request Skylight to remove his/her personal information from Skylight storage based on applicable law and Skylight’s policies.
        When Skylight delete data, Skylight will follow a deletion process to ensure that any and all information obtained by Skylight is completely removed from any space or form storage in a safe manner, or only kept anonymously. There may be a delay between when Skylight delete something and when copies of this content are removed from Skylight’s operating and backup systems.
    7. Retaining personal information
      Skylight retains a person’s personal information for as long as that person remains in a relationship with Skylight. In some cases, Skylight retains data for longer periods of time when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention, or financial record-keeping; or comply with legal or regulatory requirements; … Then, Skylight keep some information anonymously.
    8. Response to Requests for Consultation, Complaints and Requests for Disclosure, etc.
      Skylight will deal properly and expeditiously, , with any requests for consultation or  complaints about disclosure of, correction of, deletion of, requests for suspension of the use of any relevant personal information.
    9. Changes to the Privacy Policy
      The Privacy Policy may be changed from time to time, however, the rights of customers, employees, job candidates, etc. under this Privacy Policy will not be reduced without explicit consent of them. The latest version will be always publicly posted on the official website of Skylight. If the changes to this Privacy Policy are important, Skylight will notify those who need to know about these changes in the most reasonable and fastest way.

Established Nov.10, 2022
Tomoki Watabe, CEO
Skylight Consulting Vietnam Co., Ltd.

Inquiries about our personal information:
     Skylight Consulting Vietnam Co., Ltd. Public Relations
     Inquiry Form