PRIVACY POLICY

Last Updated: 10/06/2026

EMPLOYEE PRIVACY NOTICE

1. PURPOSE 

The purpose of this Notice is to transparently describe why and how LVHA as the controller and processor of the data, collects and uses your Personal Information during and after your working relationship with us, with whom we might share it and how long we usually keep it. It is also meant to make you aware of your rights under the various data privacy laws and regulations.

2. SCOPE

This Notice applies to the Personal Information of current and former employees, candidates, and consultants (collectively “Employee”) processed by LVHA, headquartered at Lot VIII-1, Road 6, Ho Nai Industrial Zone, Ho Nai Ward, Dong Nai City, Vietnam, its subsidiaries and affiliates (collectively “LVHA”). 

“Personal Information” means any information allowing a natural person to be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to their physical, physiological, mental, economic, cultural or social identity. 

3. TYPE OF PERSONAL INFORMATION COLLECTED

The type of Employee Personal Information LVHA collects, in an automated or non automated manner, uses, shares and stores depend on the nature of your position and role within LVHA and the requirements of applicable legislation (employment, tax, insurance, etc.). 

Except where restricted by local law, the applicable departments of LVHA may process the following categories of Personal Information: 

• Contact information such as name, address, telephone number, personal email address and other contact information (including emergency contact information). 
• Identification and demographic information such as date and place of birth, marital status, nationality, gender, immigration status, spoken languages, information relating to racial origin and ethnic origin, signature, driver’s license, license plate number, passport, social security number, identity card or other national identification documents, photographs, criminal records, family members, beneficiary and dependent details. Gender, race and religion, information relating to racial origin and ethnic origin will only be collected when/where required by local legislation. 
• General employment information such as evidence of your right to work, employee identification number, job title and grade level, office location, employment contract, hire/termination date, trade union memberships, performance history and succession planning, test & evaluation results, whistleblowing concerns raised by you or to which you may be a party or witness, disciplinary records as well as attendance records.
• Education and training information such as academic and professional qualifications, professional license and certifications, competency assessments, experience, CV/Resume and details of other training and development. 
• Health information such as physical and mental health records, disability details and medical reports. 
• Financial information such as bank account details, tax information, salaries, bonuses, benefits and other information required to administer payroll. Financial information also includes transaction details, expense information and pension investment details. 
• Workplace access and device, usage and content information such as emails sent and received, building and information system access, LVHA device, system and application usage (including telemetry) when accessing and using LVHA corporate buildings and assets. 
• Video, voice and image information such as video, voice and image data taken in connection with workplace functions, security purposes and promotional, marketing or advertising purposes, subject to the requirements of local law and LVHA’s internal policies (where appropriate). 

LVHA collects this Personal Information directly from its Employees and from third parties such as references, criminal record or credit reference agencies, public sources, medical professional and other professional advisory service providers. In most circumstances, LVHA will obtain your permission before we seek out this information from such sources (such permission may be given directly by you or implied from your actions). 

LVHA has put in place appropriate security measures to ensure that all Employee Personal Information is protected against loss and unauthorized access, such as firewalls and access control procedures, to protect Personal Information against loss and unauthorized access.

4. PURPOSES FOR PROCESSING PERSONAL INFORMATION 

LVHA will ensure that the Personal Information we hold about you is processed lawfully,  fairly and in a transparent way, collected and processed for the specified purposes only,  adequate, relevant and not excessive in relation to the purpose for which it was collected and  processed, accurate and up-to-date, not kept in a form which allows identification of the Employee  for longer than necessary, securely held; and shared only to those who need to know such  Personal Information to perform their obligations. 

LVHA processes the Personal Information gathered to perform our role as an employer, to enable us to comply with a legal obligation, based on legitimate interests or on any other basis permitted by law. When there is no other legal basis to collect and process Employee Personal Information, LVHA will need your consent, consent you are not obliged to provide, and which can be withdrawn at any time. 

LVHA will process your Personal Information in the following situations, among others: 

• Deciding about your employment 
• Determining the terms of your employment from onboarding to termination 
• Paying your salary and, as applicable, deducting tax, mandatory social contributions and national insurance contributions in accordance with local legislation 
• Determining performance requirements, setting individual objectives and conducting performance reviews 
• Making decisions about salary reviews and compensation 
• Assessing qualifications for a job or task, including decisions about career and promotions
• Reviewing, changing or providing additional Employee benefits, rewards and bonuses 
• Arranging for flights and accommodations, applying for visas or processing expenses 
• Establishing education, training and/or development requirements 
• Compiling directories and conducting data analytics 
• Ensuring network and company-held information security, including email backups 
• Ensuring a safe and healthy working environment 
• Complying with applicable labour or employment laws and regulations 
• Monitoring compliance with LVHA’s policies, gathering evidence of wrongdoing for disciplinary action 
• Dealing with legal disputes involving you, or other employees, workers, contractors, including work accidents.

We may use your Personal Information for purposes other than those for which it was collected if we believe that the purpose is consistent with the original purpose. If we are going to use your Personal Information for an unrelated or new purpose, we will inform you, explain the legal basis for doing so and obtain your consent, if required by law.

5. SHARING OF PERSONAL INFORMATION

LVHA will only share Employee Personal Information with those who have a legitimate need for it such as: 

• internally with appropriate LVHA personnel who require such information to assist us with managing our relationship with you. This includes, for example, members of the HR team, your manager and IT staff. 
• for legal or regulatory purposes where the disclosure of such Personal Information is required to comply with our legal or regulatory obligations. 
• with benefit providers such as a healthcare insurance company, a pension administrator, an occupational health advisor or other similar service provider required to manage the benefits and services LVHA offers to you. 
• with suppliers who may process your Personal Information on behalf of LVHA The processing of such Personal Information will remain under the control of LVHA, will be executed as per LVHA’s instructions and in full compliance with strict security requirements. 
• in other contexts, related to your job, such as to obtain pre-employment references, when you need access to digital platforms to allow you to complete your work, for sponsorships from governments or other organizations, or in the event of the possible sale or restructuring of the business. In cases like these, LVHA will limit the information shared and will try to anonymize it, when possible. 

LVHA does not allow third parties with whom we share your Personal Information to use this information for their own purposes. We will only permit them to process your Personal Information to the extent required to perform their services and in accordance with our instructions. 

Furthermore, as an international company, it may be necessary for LVHA to transfer your Personal Information in a region/country different to the one in which it was initially collected.  LVHA will ensure that such transfers of Personal Information comply with all applicable data privacy laws and regulations and that appropriate safeguards are in place. Any questions with regards to the transfer of Employee Personal Information can be addressed to LVHA’s human resources department.

6. RETENTION OF EMPLOYEE PERSONAL INFORMATION

Employee Personal Information is retained only for as long as necessary for the purpose for which LVHA obtained it including to satisfy any legal, accounting, or reporting requirements. If Personal Information is needed for more than one purpose, LVHA will retain it until the end date of the purpose with the longest duration; however, LVHA will discontinue any use of such Personal Information for purposes with earlier end dates as soon as such dates are reached. LVHA’s retention periods are based on business needs and Employee Personal Information that is no longer needed is either irreversibly anonymized or destroyed. 

7. RIGHTS AND RESPONSIBILITIES OF LVHA’S EMPLOYEES

All LVHA’s Employees have the right: 

1. To request information on how their Employee Personal Information was collected, how it is being stored and for what legitimate business purpose. 
2. To be informed if their Employee Personal Information is being shared, the recipient’s identity or the category of recipients. 
3. To request access to their Employee Personal Information or that their Employee Personal Information be corrected. 
4. To request deletion of their Employee Personal Information if the legal basis for the Processing of Personal Information has ceased to apply or if the legitimate business purpose has lapsed or ceased to be applicable for other reasons. In evaluating such request, LVHA’s business and legal archival requirements must be considered; and, 
5. To object to their Personal Information being processed when they deem that their data protection rights should prevail over the legitimate business purpose of LVHA. It is important that the information LVHA holds on its Employees is accurate and current.
6. To consent or not to consent the processing of your personal information unless in case of without the consent of the personal information in accordance with the Vietnamese law.
7. To withdraw consent, unless otherwise provided by Vietnamese law.
8. To request for deletion of your personal information
9. To request to limit the processing of your personal information, unless otherwise provided by Vietnamese law.
10. To claim damages in accordance with the law upon violation of the regulations on personal data protection, unless otherwise agreed by LVHA and employees or prescribed by Vietnamese law.
11. To self-defences in accordance with Vietnamese law.
12. To complain, denounce and/or initiate lawsuits.

All LVHA’s Employees have obligations:

1. To self-protect their own personal information.
2. To respect and protect others’ personal information.
3. To fully and accurately provide personal information upon giving consent to the personal information processing.
4. To take part in training of skills for personal data protection (if any).
5. To comply with LVHA’s regulations and the law on personal information protection.

It is your responsibility to make sure that your Personal Information is up-to-date and complete. Changes can be made directly in your employee file or by contacting LVHA’s human resources department.  

In case of questions, complaints and/or allegations of violations with regards to LVHA’s requirements on the processing of Personal Information or to exercise their rights, Employees may contact LVHA’s human resources department.  

8. POTENTIAL AND UNWANTED CONSEQUENCES AND/OR DAMAGE:

When handling requests regarding your rights:

You have the rights specified in Article 7 above and may request LVHA to exercise these rights while processing your personal data. At this stage, LVHA may require a reasonable period (depending on the complexity and impact of your request on the relationship between LVHA and yourself) to process your request and/or to inform you of any potential consequences or unintended damage that may result from fulfilling your request.

Please be advised that if you do not provide certain Personal Information when requested, LVHA may not be able to fully perform the contract we have entered with you such as being able to pay you, provide a benefit or comply with legal obligations. 

In processing your data:

LVHA implements measures to protect and handles your personal data in compliance with legal regulations. In rare instances, breaches in the processing of personal data (such as loss, destruction, or damage due to incidents or the use of technical measures) may occur, which are entirely unintended. Within the framework of the law, LVHA will notify relevant parties of any breaches within the legally prescribed timeframe. Compensation for any damages resulting from violations of data protection regulations will be provided in accordance with agreements or legal requirements.

9. REVIEW 

The Notice will be reviewed periodically, as required, and it can be amended at any time. Upon updating or amending this Notice, the most recent version of this Notice will be made available to all LVHA’s Employees and the date at the top will reflect the last time that updates or amendments were made. 

10. REVISION HISTORY