Privacy and Personal Data Policy

1. Havas commits to protect your personal data

Havas Group Vietnam Limited Liability Company (“us”, “we”, “our”, “Havas”) is committed to protecting your personal data and your privacy. We comply with the requirements of the Decree 13/2023/ND-CP on Protection of Personal Data (the “Decree 13”) to collect, hold, use and process your personal data. We encourage you to carefully read this Privacy Policy Statement (the “Policy”).

The meaning of “personal data” in this Policy shall have the same meaning as defined in the Decree 13. Generally, personal data means information which relates to an individual and can be used to identify that individual. This Policy informs you of our data protection and privacy practices and the way your personal data is collected, held, used and processed by Havas. This Policy will be readily available on our home page and at the bottom of each page of this website.

2. Collection of Personal Data Statement

a. How do we collect, hold, process and use your personal data?

Havas respects the rights of each individual to have their privacy and personal data protected. We will keep your personal data confidential. We take appropriate steps to protect personal data we hold against loss, unauthorized access, use, modification or disclosure.

Havas will observe the following principles when we collect, hold, process and use your personal data:

• We collect your personal data in a lawful and fair way, for specified and lawful purposes. The personal data collected is relevant to and not excessive for the purposes for which it is collected and used.
• We seek to maintain your personal data accurate, and where necessary, up-to-date. We will take practicable steps to correct inaccurate or incomplete data.
• We keep your personal data only for the duration as it is necessary for the purposes for which it is collected and used and as permitted or required by the applicable law.
• We only use your personal data for the purpose for which it is collected or for a directly related purpose.
• We take appropriate technical and organisational security measures to keep your data safe and prevent unauthorised access, processing, loss or use.
• We process your personal data in accordance with the legal bases for processing.

b. Why we collect and for what purposes we use your personal data?

Havas may collect personal data from you for the following purposes:

• Browsing and Searching: We collect certain personal data when you visit the website or click on the various links for services. We collect those data to improve your web user experience for your next visits (ex: country selection, language), to help run the sites more efficiently, to gather broad demographic information, to monitor the level of activity on the websites, and to evaluate the effectiveness of our advertising. See also our Cookies Policy for our use of cookies.
• Contact information: If you contact us, we keep a record of your correspondence or comments, including personal data, in a file specific to you. We use these data to help us provide you better service in the event you contact us again.

c. What data is collected?

Havas collects and uses your personal data with appropriate notice and consent when it is required, and after having informed you in a proper way. The types of personal data we collect from you may include:

• your name, surname, age, gender, company, email address, phone number (in case you contact and provide us your data)
• online identifiers (cookie id, pixels, IP address); and
• website navigation behaviour.

You have the right to decide whether you provide your personal data to us and are not obliged to do so. If you do not provide us with the requested personal data or if the personal data provided by you is inadequate or inaccurate, we may not be able to provide you with the services of Havas.

d. How long data is processed and storaged?

• Duration of data processing: From the time Havas starts receiving and/or collecting your personal data until (whichever comes last):
  1. There is your written request.
  2. Legal agreement between you and Havas is terminated or the Parties have fulfilled all obligations related to agreements.
  3. Disputes, complaints have concluded with a valid agreement/judgment/decision of a competent state agency.
  4. The processing purpose has been completed with your consent.
  5. The archival obligation has been fulfilled as prescribed by law.
  6. As required by legal regulations.
• Storage of your personal data: Havas will apply methods for storing your personal data for the period necessary to fulfill the purpose as stated in this Policy.

e. Disclosure/transfer of personal data

Havas use external providers which may have access to your personal data. Where disclosure of personal data is necessary to satisfy the purpose of using your personal data, we may provide such personal data to:

• agents, contractors, suppliers and any third-party service provider who provides administrative, marketing and research, distribution, data processing, telemarketing, telecommunications, computer, payment or other services to Havas in connection with our operations;
• business partners for such purposes in relation to promotion or direct marketing; and
• government and regulatory authorities and other organisations, as required by law, by court order or in response to any legally valid inquiry, or otherwise necessary to the establishment of the legal claims or defences, to obtain legal advice or to exercise and defence Havas’s legal rights.

Havas may, in this regard, conclude contractual clauses with the recipients of such data to ensure that appropriate safeguards are taken regarding the protection of your personal data.

f. Links to third-party websites

Havas websites or services may provide links to third-party applications, products, services, or websites for your convenience and information. If you access those links, you will leave the Havas website. Havas does not control those third-party websites or their privacy practices, which may differ from our practices. We do not endorse or make any representations about third-party websites. The personal data you choose to provide to or that is collected by these third parties are not covered by this Policy. We encourage you to review the privacy policy of any website you interact with before allowing the collection and use of your personal data. We may also provide social media links that enable you to share data with your social networks and to interact with Havas on various social media sites. Your use of these links may result in the collection or sharing of data about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the data that may be collected, used, and shared by those sites. If you post, comment, indicate interest, or share personal data, including photographs, to any public forum, social network, blog, or other such forum, please be aware that any personal data you submit can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor Havas have control over. Havas is not responsible for the personal data you choose to submit in these forums.

g. Your data protection rights

• Your right to know. In this respect, you have the right to know about your personal data processing activities, unless otherwise provided by regulations.
• Your right of access. In this respect, you are entitled to access to view, correct or request correction of your personal data, unless otherwise provided for by regulations.
• Your right to withdraw consent. When the data processing operations we implement are based on your consent, you can withdraw it at any time. We then stop processing your personal data without the previous operations to which you had given your consent being called into question.
• Your right to have your data erased. You can ask us to erase your personal data in the cases provided for by the regulations. Please note that the right to erase data is not a general right and that it can only be granted if one of the reasons provided for in the applicable regulations is present.
• Your right to restrict data processing. You may request the processing of your personal data to be restricted in the cases provided for by the regulations.
• Your right of data provision. You may request us to provide you with your personal data, unless otherwise provided for by law.
• Your right to object data processing. You may object to us, the data controller specified in this Policy from processing your personal data in writing to Havas, the data controller in order to prevent or limit the disclosure of the personal data or use the personal data for advertising and marketing purposes, unless otherwise provided for by law.
• Your right to complain, denounce, initiate lawsuits. You may complain, denounce or initiate lawsuits in accordance with the regulations.
• Your right to claim compensation. You may claim compensation for actual damage in accordance with the regulatins if Havas commits a violation of the regulations on the protection of your personal data, unless otherwise agreed by the parties or otherwise provided by law.
• Your right to consent. You may or may not consent to the processing of your personal data, unless otherwise provided by regulations.
• Your right of self-protection. You may protect yourself according to the provisions of the Civil Code, other relevant laws, or request competent authorities or organizations to implement civil rights protection methods as prescribed in Article 11 of the Civil Code.

* You can exercise your rights with the Havas DPO:

at the email address: vn-hvs-hcmc-contact@havas.com

or by post to: Havas Data Protection Officer, Floor 3, Bao Gia Tower, 184 Le Dai Hanh, Ward 15, District 11, Ho Chi Minh City, Vietnam.

3. Changes to the Policy

Havas reserves the right to modify the Policy as needed, for example, to comply with changes in laws, regulations, Havas’s practices and procedures, or requirements imposed by data protection authorities.

If there is any inconsistency or conflict between the English version and the Vietnamese version of the Policy, the English version shall prevail.

Last update: April 2024