Privacy Policy
GAP Global Technology Joint Stock Company
GAP Global Technology Joint Stock Company ("GAP Global", "we", "us", or "our") is committed to protecting the privacy and personal data of our clients, candidates, partners, employees, and website users in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 ("GDPR") where applicable, and Vietnam's Law on Cybersecurity and relevant personal data protection regulations.
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you interact with our company, services, or website.
1. Who We Are
GAP Global Technology Joint Stock Company is a technology company headquartered in Vietnam, specializing in:
• Software Development & Engineering
• Software Outsourcing & IT Services
• Employer of Record (EOR)
• Payroll Management & HR Solutions
Registered Office: Vietnam
Privacy Contact: [email protected]
2. Personal Data We Collect
Depending on the nature of your interaction with GAP Global, we may collect the following categories of personal data:
2.1 Clients & Business Partners
• Full name and job title
• Company name and business email
• Phone number (including messaging apps)
• Business requirements and project-related information
• Contract and billing details
2.2 Candidates & Employees
• Full name and contact information
• CV/resume, employment and educational history
• Salary expectations and compensation details
• Identification documents (where legally required)
• Tax code and social insurance information (for EOR/Payroll services)
• Bank account details (for salary disbursement)
• Performance-related data (where applicable)
2.3 Website & Platform Users
• IP address and device/browser information
• Cookies and usage/analytics data
• Form submissions and communication history
3. How We Collect Data
We collect personal data through the following channels:
• Website contact forms, registration forms, and job application portals
• Direct communication via email, phone, LinkedIn, or messaging applications
• Signed contracts, agreements, and onboarding documentation
• Business meetings, webinars, and networking events
• Referrals from existing clients, partners, or employees
• Analytics tools such as Google Analytics or similar technologies
• Integration with third-party platforms used to deliver our services
4. Purpose and Legal Basis for Processing
We process personal data based on one or more of the following legal grounds:
• Consent — for marketing communications, newsletter subscriptions, and candidate profile storage
• Performance of a contract — for software development, outsourcing, EOR, and payroll service delivery
• Legitimate interests — for business development, talent sourcing, and service improvement
• Legal obligations — for compliance with Vietnamese labor law, tax regulations, social and health insurance requirements
Specifically, we use personal data to:
• Respond to service inquiries and business requests
• Deliver software development, outsourcing, EOR, and payroll services
• Manage employment contracts and HR documentation
• Process payroll, tax filings, and social insurance contributions
• Send service updates and marketing communications (with consent)
• Improve our technology platforms, website, and service quality
• Ensure information security and prevent unauthorized access or fraud
5. Data Sharing and Third Parties
Important: GAP Global does not sell personal data to any third party.
We may share personal data with:
• Client companies — for recruitment, staffing, or software project delivery purposes (with candidate/employee consent where required)
• Payroll processors, banks, and insurance providers — for employment-related financial and administrative services
• Government authorities and regulatory bodies — where required by Vietnamese law or applicable international regulations
• Technology and cloud service providers — under strict confidentiality and data processing agreements (e.g., cloud hosting, CRM, project management tools)
• Trusted legal, accounting, and audit professionals — bound by professional confidentiality obligations
All third parties are required to handle personal data in compliance with applicable data protection laws and our internal data protection standards.
6. International Data Transfers
Where personal data is transferred outside Vietnam or the European Economic Area (EEA) — for example, in the context of cross-border software outsourcing or EOR services — we ensure appropriate safeguards are in place, including:
• Standard Contractual Clauses (SCCs) as approved by the European Commission
• Data Processing Agreements (DPAs) with all relevant parties
• Confidentiality agreements with service providers and partners
• Internal data governance policies aligned with international best practices
7. Data Retention
We retain personal data only for as long as necessary to:
• Fulfil the purposes for which it was collected (service delivery, recruitment, payroll processing)
• Comply with contractual obligations between GAP Global and its clients or employees
• Meet applicable legal, tax, labor, and social insurance requirements under Vietnamese law
• Resolve disputes and enforce our agreements
Candidate profiles may be retained for future recruitment opportunities unless a deletion request is received. Employee records related to payroll and tax filings are retained in accordance with Vietnamese statutory requirements.
8. Your Rights
Depending on the applicable laws (including GDPR where relevant), you may have the following rights regarding your personal data:
• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten"), subject to legal obligations
• Right to Restriction: Request that we limit processing of your data under certain circumstances
• Right to Object: Object to processing based on legitimate interests or for direct marketing purposes
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Withdraw Consent: Withdraw consent at any time without affecting prior processing
• Right to Lodge a Complaint: File a complaint with the relevant supervisory or data protection authority
To exercise any of your rights, please contact us at: [email protected]
9. Data Security
GAP Global implements appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or disclosure. These measures include:
• Secure servers, encrypted data transmission (TLS/SSL), and encrypted storage for sensitive information
• Role-based access controls and multi-factor authentication for internal systems
• Confidentiality agreements with all employees, contractors, and third-party vendors
• Regular security reviews, vulnerability assessments, and internal audits
• Incident response procedures to detect and address data breaches promptly
10. Cookies and Tracking Technologies
We use cookies and similar tracking technologies on our website and platforms to:
• Enhance user experience and remember your preferences
• Analyze website traffic and measure service performance
• Support security features and detect fraudulent activity
You may manage or disable cookies through your browser settings. Please note that disabling cookies may affect the functionality of certain features on our website. For more details, please refer to our Cookie Policy.
11. Children's Privacy
Our services are intended for business clients, professionals, and adults aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has provided us with personal data, please contact us immediately at [email protected] so we can take appropriate action.
12. Updates to This Policy
GAP Global Technology may update this Privacy Policy from time to time to reflect changes in our services, applicable laws, or data protection practices. The most recent version will always be published on our website with the updated effective date. We encourage you to review this Policy periodically.
Continued use of our services after any updates constitutes acceptance of the revised Privacy Policy.
Contact Us
GAP Global Technology Joint Stock Company
Email: [email protected]
We will respond to all privacy-related inquiries within 30 working days.