1. Purpose and principles of this policy
This Policy is intended to ensure transparency between you and VIXION. By accessing the Website or using Vesper Applications, you understand that we process data based on the following principles:
This Policy is established in accordance with applicable Vietnamese law, including but not limited to regulations on personal data protection, electronic transactions, network information security, and cybersecurity, including the Law on Personal Data Protection No. 91/2025/QH15 and its implementing regulations as applicable from time to time.
- Lawfulness and fairness.
- Clear purpose limitation.
- Data minimization (collecting only what is necessary).
- Appropriate technical and organizational measures to protect personal data.
2. Scope of application and the local-first mechanism
2.1. This Policy applies to all data arising from the operation of the Website and the Vesper application.
2.2. Local-first mechanism: Under the local-first mechanism, Vesper does not proactively access, collect, or store users’ work data in the locally operated version, except where required by law or where users voluntarily provide information for support purposes.
3. Types of data we may collect
3.1. Data voluntarily provided by you: To provide support services, we collect: full name, email address, phone number, organization name, title, and details of your specific request. You may refuse to provide such information; however, this may affect our ability to support you or provide services.
3.2. Website technical data: Technical information such as IP address, browser type, and access time is automatically collected for system analysis. This data is anonymized and used to help prevent cyberattacks.
3.3. Commercial interaction data: This includes consultation history and survey responses. We retain this information to ensure continuity in customer care services.
3.4. Information you should not send: We recommend that you do not submit sensitive data (such as detailed financial information or confidential business documents) through public forms on the Website.
4. How we collect data
4.1. Direct collection from you: We may collect personal data when you voluntarily provide information to VIXION through the Website, application, email, contact forms, trial registration forms, consultation registrations, information subscription forms, technical support requests, survey responses, or other contact channels made available by VIXION from time to time.
4.2. Collection during your use of the Website: When you access and use the Website, certain technical data may be collected automatically for the purposes of operation, security, analytics, performance optimization, and user experience improvement. This data may include, but is not limited to, IP address, browser type, operating system, device language, access time, session duration, pages viewed, referral source, basic interactions on the Website, and related system log data.
4.3. Collection through cookies and similar technologies: We may use cookies, pixels, tags, SDKs, or similar technologies to remember your preferences, maintain login sessions, analyze browsing behavior, measure content effectiveness, detect technical issues, and improve the quality of the Website. The use of these technologies is carried out in accordance with the purposes stated in this Policy and applicable law.
4.4. Collection through analytics tools and technical infrastructure: VIXION may use third-party analytics, monitoring, or operational support tools, such as traffic measurement tools, email infrastructure, storage infrastructure, security infrastructure, or customer support tools. In that process, certain technical data or your contact data may be recorded or processed to the extent necessary to operate the Website, respond to requests, and improve services.
4.5. Collection from support contact or commercial communications: When you send emails, make phone calls, send messages, submit request forms, or communicate with VIXION’s team regarding products, services, demos, quotations, payments, or technical support, we may collect and retain the content of such communications, contact information, response history, and other related information to process requests, maintain continuity of service, and support the resolution of arising issues.
4.6. Collection from sources authorized or permitted by you to share data: In certain cases, we may receive personal data from organizations, enterprises, lawful representatives, system administrators, or third parties whom you have consented to, authorized, or permitted to share data with VIXION for the purposes of account setup, deployment support, technical support, customer care, or other lawful purposes related to the provision of the Services.
4.7. Data arising from the local-first mechanism: For the locally operated version of the Vesper application, work data, including but not limited to input, output, internal files, or content processed directly in the local environment, will in principle be stored and processed on devices or environments controlled by the user or customer. VIXION does not proactively access or collect such data, except where: (i) you voluntarily send it to us to request support; (ii) a specific configuration or feature is activated at your request; or (iii) required by law or by a competent state authority.
4.8. Data you should not submit through public channels: Unless expressly requested under an appropriate security process, you should not submit through public forms or standard support emails any sensitive data or data with a high level of confidentiality, such as detailed financial information, trade secrets, sensitive personal data, account authentication information, or confidential organizational documents. If you voluntarily provide such data, you confirm that doing so is necessary and appropriate for the relevant contact purpose or support request.
4.9. Data minimization principle in data collection: To the extent possible, VIXION applies the principle of data minimization, meaning that only data that is necessary, appropriate, and directly relevant to the stated processing purposes will be collected. We do not intentionally collect data beyond what is necessary for operating the Website, providing the Services, supporting users, or complying with legal obligations.
5. Purposes of data processing
Your data is processed for the following purposes:
- 5.1. To respond promptly to customer requests.
- 5.2. To administer the Website and maintain system security.
- 5.3. To improve software features based on aggregated data or data that has been processed to limit identifiability.
- 5.4. To fulfill contractual and legal obligations with state authorities.
- We do not use your personal data beyond the scope that has been notified or in violation of applicable law.
6. Legal bases for data processing
We process data on one or more appropriate legal bases, including:
- Your consent.
- The need to take necessary steps at your request before entering into a contract or agreement.
- Legal obligations that VIXION must comply with.
- VIXION’s legitimate interests, provided that such processing does not disproportionately affect the lawful rights and interests of the data subject.
9. Cross-border data transfers
Where necessary, certain data may be stored or processed on systems, servers, or by service providers located outside the territory of Vietnam. In such cases, VIXION will apply appropriate legal, technical, and organizational measures in accordance with applicable Vietnamese law on personal data protection.
10. Data retention period
We retain data only for as long as necessary to fulfill the stated purposes or for the period required by law (for example, retention of invoices and tax documents). After that, the data will be permanently deleted.
11. Rights of the data subject
11.1. General principle: To the extent permitted by applicable law, you, as the data subject, have rights relating to your personal data processed by VIXION. VIXION respects and facilitates your exercise of these rights in accordance with the procedures, process, and scope permitted under applicable law.
11.2. Right to be informed: You have the right to be informed about the processing of your personal data, including but not limited to: the types of data being processed, purposes of processing, legal bases for processing, data recipients, retention period, scope of use, and other important matters related to data processing as required by law.
11.3. Right to consent and withdraw consent: Where data processing is based on your consent, you have the right to consent to or refuse the processing of your personal data. You also have the right to withdraw consent at any time, except where otherwise provided by law or where the data processing is carried out on another lawful basis independent of consent. Withdrawal of consent does not affect the lawfulness of processing already carried out before the withdrawal.
11.4. Right to access, review, correct, and update data: You have the right to request access to, review, correction, updating, or supplementation of your personal data if such data is inaccurate, incomplete, or outdated, provided that exercising this right does not infringe the lawful rights and interests of VIXION or third parties, and does not fall within cases restricted by law.
11.5. Right to request deletion of data: You have the right to request deletion of your personal data in cases permitted by law, including where the data is no longer necessary for the stated processing purposes, the processing no longer has an appropriate lawful basis, or you withdraw consent and no other lawful basis for processing exists. However, VIXION may continue to retain certain data to the extent necessary to comply with legal obligations, resolve disputes, protect its lawful interests, or serve retention purposes permitted by law.
11.6. Right to request restriction of data processing: You have the right to request that VIXION restrict the processing of personal data in certain cases, for example where you believe the data is inaccurate, the processing exceeds the necessary scope, or you object to the ongoing processing activity. During the review of such a request, VIXION may continue to retain the data or process it at a minimum level necessary to ensure system security, prevent fraud, comply with law, or protect the lawful rights and interests of relevant parties.
11.7. Right to object to data processing: To the extent permitted by law, you have the right to object to the processing of your personal data if you have grounds to believe that such processing is no longer appropriate, exceeds the stated processing purpose, or unreasonably affects your lawful rights and interests. VIXION will review the objection and provide an appropriate response in accordance with applicable law.
11.8. Right to complain, denounce, and claim compensation: You have the right to complain, denounce, or claim compensation for damages in accordance with law if you believe that your personal data has been processed unlawfully, for an improper purpose, beyond the proper scope, or in a way that causes damage to your lawful rights and interests.
11.9. How to exercise your rights: To exercise the above rights, you may submit a request to VIXION through the contact details provided in Section 16 of this Policy. The request should include at least the minimum information necessary for us to identify the requester, the content of the request, the scope of relevant data, and the preferred method of response.
11.10. Verification of identity and authority: Before processing a request related to personal data, VIXION may require you to provide additional information or appropriate documents to verify identity, the relationship to the data, or authority of lawful representation. Where reasonable verification cannot be completed, VIXION may refuse or suspend processing of the request until verification is completed.
11.11. Response and processing timeframe: VIXION will receive, review, and respond to your request within a period appropriate under applicable law or within a reasonable period depending on the nature, scope, and complexity of the request. In certain cases requiring additional time for verification, technical handling, or coordination with relevant parties, the processing time may be extended; in such case, VIXION will notify you as appropriate.
11.12. Limits on the exercise of rights: Certain rights of the data subject may be restricted, delayed, or refused in cases permitted by law, including but not limited to cases involving protection of trade secrets, technical secrets, system security, lawful rights and interests of third parties, statutory retention obligations, or requests of competent state authorities.
11.13. No fee, except in reasonable cases: VIXION does not charge fees for reasonable requests related to the exercise of data subject rights. However, in cases of excessive repetitive requests, requests lacking proper grounds, requests causing disproportionate technical burden, or requests requiring special processing costs, VIXION may take appropriate measures in accordance with law, including refusing to process the request or requiring reasonable costs if permitted by law.
12. Data security and incident handling
VIXION applies appropriate technical and organizational measures to protect personal data. In the event of an incident affecting personal data, VIXION will assess the incident, implement appropriate remedial measures, and notify the data subject and/or competent authorities in accordance with applicable law.
13. Minors
This Website is primarily intended for organizations, enterprises, and users for work-related purposes. VIXION does not intentionally collect personal data of children or minors in violation of applicable law. If you believe that data of a child or minor has been provided to VIXION inappropriately, please contact us so that we may review and handle the matter in accordance with law.
14. Links to third parties
The Website may contain links to third-party websites or services. VIXION does not control and is not responsible for the data processing policies, content, or activities of such third parties. You should carefully review their policies before providing any data.
15. Updates to this policy
VIXION may amend, supplement, or update this Policy from time to time to reflect changes in law, operating model, technical characteristics, or configuration of Vesper. The updated version will be posted on the Website together with a new effective date.
Where required by law or where changes materially affect the rights and interests of the data subject, we will provide additional notice or seek opinions/consent in accordance with law. To the extent permitted by law, your continued use of the Website after this Policy has been updated may be understood to mean that you have been notified of the updated version.
16. Contact information
If you have any questions or requests relating to this Privacy Policy, please contact:
VIXION COMPANY LIMITED
Address: 10th Floor, Miss Ao Dai Building, 21 Nguyen Trung Ngan Street, Sai Gon Ward, Ho Chi Minh City, Vietnam
Contact / privacy / support email: hello@vixion.vn