Personal Data Processing

This page sets out in detail how Cluvix Solutions Co., Ltd processes personal data under Decree 13/2023/ND-CP. It supplements our Privacy Policy, focusing on how data moves through our systems and how you exercise your rights.

1. Legal basis for processing

We process personal data on the basis of the data subject consent, given by ticking the confirmation box on the contact form before submitting. Without that tick the form does not send, so no data is collected without your intent.

2. The processing flow

Step one. You complete the form on the website. Data is sent over an encrypted connection to the website server.

Step two. The website server passes the data to an internal management system that we operate, hosted in Vietnam. The website server keeps no copy of the form content.

Step three. The team responsible for the reason you selected receives and responds. Only staff responsible for that request can see the data.

3. Purpose by type of request

Product or service: advising, estimating scope and cost, and discussing whether we are a fit.

Recruitment: reviewing your application and arranging an interview. We keep the link you provide and do not download the file ourselves. Application data is used only for recruitment, not for commercial purposes, and is not passed to external recruitment agencies.

Other enquiries: answering the question you asked.

4. Withdrawing consent, correction and deletion

Send your request to contact@cluvixsolutions.com or call 0976 365 284, including the email address or phone number you used on the form so we can identify the right record.

Our handling process: the person receiving the request verifies the identity of the data subject, locates the corresponding record in the internal system, carries out the correction or deletion, removes the related correspondence from our internal mailbox, and replies to you through the channel you used.

The whole process completes within 72 hours of receiving the request, as required by Articles 14 and 16 of Decree 13/2023/ND-CP. This process is carried out manually by the responsible person; it is not automated.

Where law requires part of the data to be retained, for example accounting records relating to a signed contract, we identify that data and the legal basis in our reply.

5. In the event of a data incident

If we discover personal data has been accessed, disclosed or lost without authorisation, we: contain the incident on discovery; determine the scope of data and the number of data subjects affected; notify the Department of Cybersecurity and High-Tech Crime Prevention (A05), Ministry of Public Security, no later than 72 hours after the breach occurs, as required by Decree 13/2023/ND-CP; and notify the affected data subjects through the contact details they provided, stating which data was involved and what we have done.

Where notification is later than 72 hours, we include the reason for the delay.

6. Data we do not collect

The website does not collect sensitive personal data as defined by Decree 13/2023/ND-CP. It sets no tracking cookies, installs no third-party analytics or advertising tools, and does not record your actions on the page.

7. Contact

Cluvix Solutions Co., Ltd, 60/17/65B Lo O Street, Noi Hoa 1 Quarter, Dong Hoa Ward, Ho Chi Minh City. Email contact@cluvixsolutions.com, phone 0976 365 284.