Personal Data Protection Policy

Last updated 30 August 2026

This policy follows Law No. 91/2025/QH15 on Personal Data Protection (in force from 1 January 2026) and Decree No. 356/2025/ND-CP.

1. Data controller

  • ALA HUMAN RESOURCE DEVELOPMENT AND INTERNATIONAL COOPERATION JOINT STOCK COMPANY (ALA HR., JSC)
  • Enterprise registration number: 0110535223
  • Registered head office: No. 132 Phuong Trach, Vinh Ngoc Commune, Dong Anh District, Hanoi, Vietnam
  • Operating office: Room 405, Thang Loi Building, No. 3 Le Thanh Tong, Ngo Quyen District, Hai Phong, Vietnam
  • Data protection contact: contact@akayprogram.org · 0328 127 277

2. Data we process

Basic personal data: full name, date of birth, sex, phone number, Zalo, email, residential address, photograph, passport and identity document details, qualifications, work history, job preferences, and an emergency contact.

Sensitive personal data: medical examination and test results required by the departure procedure and by the employer, and judicial record certificates. We process these only with your separate consent and only to the extent the procedure requires.

We collect only data directly relevant to advising you, introducing you and preparing your file, consistent with Article 25 of the Law on Personal Data Protection.

3. Purposes

  • Advising you and assessing which roles you are suitable for
  • Introducing your profile to employers and partners
  • Preparing and submitting work permit, visa and related applications
  • Contacting and supporting you during processing and after arrival in Poland
  • Meeting legal obligations and requests from competent authorities

4. Legal basis

We rely on your consent, on performance of a contract or steps taken at your request before entering one, and on compliance with legal obligations. You may withdraw consent at any time. Withdrawal does not affect the lawfulness of earlier processing, but it may mean we can no longer progress your application.

5. Who receives your data

  • Employers in Poland and the EU to which you apply
  • The licensed Vietnamese dispatch enterprise handling the departure procedure
  • A licensed Polish employment agency (agencja pracy) where the procedure requires it
  • Competent authorities of Vietnam and Poland, and consular offices
  • Service providers such as translators, notaries, medical facilities, and IT and storage providers

We do not buy or sell personal data.

6. Transfers outside Vietnam

To arrange introductions and work permit applications, your data will be transferred to Poland and other European Union countries. This is necessary for your application to be processed.

We prepare and retain a cross-border transfer impact assessment dossier as required, and we require recipients to apply corresponding safeguards. Data transferred into the European Union also receives the protection of the General Data Protection Regulation (GDPR).

7. Retention

  • If you are not hired, we delete your data in line with Article 25 of the Law on Personal Data Protection, unless you agree that we may keep it to introduce other opportunities. Where you agree, we keep it for a maximum of 24 months from our last contact.
  • If you are hired, we retain your data for as long as needed to support you and to meet statutory record-keeping obligations.
  • At the end of the retention period, data is deleted or anonymised.

8. Your rights

You have the right to be informed; to consent and to withdraw consent; to access, view and obtain a copy; to correct; to delete; to restrict processing; to object to processing; to request provision of your data; to complain, denounce or sue; and to claim compensation.

Response times under Decree No. 356/2025/ND-CP:

  • Withdrawal of consent, restriction of processing, objection to processing: we respond within 2 working days and complete within 15 days (up to 20 days where a third-party processor is involved)
  • Viewing, correcting or providing data: completed within 10 days

Send requests to contact@akayprogram.org. We may ask you to verify your identity first.

9. Security

We apply technical and organisational measures including role-based access control, limiting the number of people who can view candidate files, and confidentiality obligations on staff and collaborators. No method of transmission or storage is completely secure. If a data breach occurs we will notify the competent authority and affected individuals as required.

10. Cookies

The Website uses cookies to operate and to measure traffic. You can disable cookies in your browser, though some functions may not work fully.

11. Minors

Our services are for people aged 18 or over. We do not knowingly collect data from minors. If we find that we have, we delete it.

12. Complaints

You may complain about our handling of your data to contact@akayprogram.org. You also have the right to complain or denounce to the competent Vietnamese authority for personal data protection, or to bring court proceedings.

13. Changes

We may update this policy. Updates are posted on this page with the revision date.

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