PERSONAL DATA CONFIDENTIALITY AND PROTECTION COMMITMENT

Article 1. Legal basis, purpose, and scope of application

This Commitment is made pursuant to Decree No. 13/2023/ND-CP dated April 17, 2023 of the Government of Viet Nam on Personal Data Protection, the Civil Code, the Labor Code, and other relevant legal documents of Viet Nam. This Commitment aims to establish confidentiality obligations, personal data protection obligations, and legal responsibilities with respect to the access, management, and processing of personal data under the management of PureHigh, ensuring that personal data is used for the correct purposes, within proper authority, and in compliance with applicable laws.

This Commitment is mandatory and applies to all organizations and individuals having an employment relationship, cooperation relationship, or service provision relationship with PureHigh, including but not limited to technology partners, service providers, members of the Board of Directors, employees, collaborators, and other organizations or individuals who have the right or the ability to access personal data of PureHigh, regardless of the form, duration, or location of work performance.

Article 2. Definitions

For the purposes of this Commitment, “PureHigh” refers to PureHigh Company Limited, which is the organization responsible for managing, operating, and bearing responsibility for training and consulting activities, technology systems, digital platforms, and data generated during its operations.

“Committing Party” means any organization or individual bound by this Commitment.

“Personal Data” means information in the form of symbols, letters, numbers, images, sounds, or similar forms associated with or capable of identifying a specific individual, in accordance with the provisions of Decree No. 13/2023/ND-CP.

“Customer” means any individual or organization that uses, registers to use, or is directly related to the use of services lawfully provided by PureHigh, including but not limited to training services delivered through courses, consulting services, coaching services, professional training, skills training, or other services that are confirmed to be provided by PureHigh through written documents, contracts, electronic agreements, or via platforms and systems managed and operated by PureHigh.

“Processing of Personal Data” means one or more operations performed on personal data, including the collection, recording, storage, modification, use, provision, sharing, transmission, deletion, or destruction of personal data in accordance with applicable laws.

Article 3. Scope of protected personal data

The personal data protected under this Commitment includes all personal data of customers that arises in connection with PureHigh’s provision of services, organization of training and consulting activities, operation of systems, and performance of other lawful activities. This scope includes personal identification data, contact information, service usage information, training records, learning outcomes, feedback, communications, system access data, and other information determined by law to be personal data subject to confidentiality and protection.

Article 4. Principles of access to and processing of personal data

The Committing Party may only access and process personal data within the scope of duties, authority, or tasks assigned or permitted in writing by PureHigh. Access to and processing of personal data must comply with the principles of necessity, appropriateness, and proper purpose. The Committing Party shall not expand the scope of use, nor arbitrarily copy, extract, aggregate, or use personal data for any purpose other than the approved purpose.

Article 5. Commitment not to use personal data for improper purposes

The Committing Party commits not to use personal data under the management of PureHigh for personal purposes, private purposes, commercial purposes, or any other purposes not directly related to the assigned duties or tasks. The Committing Party shall not exploit, analyze, aggregate, train systems, develop products, provide services, or generate any material or non-material benefits from PureHigh’s personal data without prior lawful written approval from PureHigh.

Article 6. Commitment not to provide or disclose personal data

The Committing Party commits not to provide, disclose, share, or transfer personal data to any other organization or individual in any form. The provision or sharing of personal data shall only be permitted where there is a written request from a competent state authority or prior written approval from PureHigh, in accordance with applicable personal data protection laws.

Article 7. Confidentiality and personal data protection obligations

The Committing Party is responsible for applying appropriate administrative and technical measures to ensure the security of personal data and to prevent risks of unauthorized access, loss, leakage, alteration, or destruction of data. In the event that a personal data security breach is detected or suspected, the Committing Party must promptly notify PureHigh and cooperate in implementing necessary measures to address and mitigate any potential damage.

Article 8. Duration of confidentiality obligations

The confidentiality and personal data protection obligations under this Commitment take effect from the time the Committing Party begins accessing personal data and continue throughout the duration of the employment or cooperation relationship. These obligations shall remain binding even after the termination of such relationships, regardless of the reason for termination.

Article 9. Responsibilities and handling of violations

In the event that the Committing Party violates this Commitment, depending on the nature and severity of the violation, PureHigh has the right to apply internal disciplinary measures, terminate contracts, claim full compensation for damages incurred, and request competent state authorities to handle the violation in accordance with the law. The handling of violations does not exclude the civil, administrative, or criminal liabilities of the Committing Party under Vietnamese law.

Article 10. Effectiveness

This Commitment takes effect from the time the user accesses or uses the website and constitutes an integral part of PureHigh’s Terms of Use, Privacy Policy, and other applicable policies.

By accessing or continuing to use the website, the user confirms that they have read and fully understood the contents of these policies, clearly acknowledge their rights, obligations, and legal responsibilities, and agree to comply with all provisions herein.