Privacy explained in plain language
The sections below contain the complete policy for the advertisements, messages and free reports described in this document.
What this Policy covers
This Policy explains how LotusGuard Vietnam Advisory handles information that people send to us through our advertisements on Meta platforms and through the messaging channels connected to them, including Facebook Messenger, Instagram Direct and WhatsApp.
It covers the whole of that path: the enquiry itself, the conversation that follows, and the free report we prepare if one is asked for — including the documents needed to prepare it.
It applies to everyone who contacts us through those channels, wherever they live, and whether or not they go on to become a client.
It does not cover our website and any measurement tools used on it, nor the files opened once a person engages us for paid work. Those are dealt with separately.
It is written to be read rather than filed. If a sentence in it is unclear, that is a fault in the writing and we would like to know.
What information do we collect?
Only what is needed to answer the person in front of us, and to prepare what they asked for. In practice, that is:
The name, email address and telephone number shown on an advertisement form, whether filled in automatically by the platform or typed by the person.
The answers given to the questions in that form.
The content of messages sent to us through the messaging channels named above, including anything a person chooses to attach.
The record the platform passes to us with each enquiry: the time it was made and which advertisement it came from.
Where a free report is asked for, the further details and documents set out in the next section, together with a note of what was discussed.
Records of this kind are kept under a file reference rather than under a person's name wherever the work allows.
Nothing is collected by observation. We do not track people across other websites or applications, and we do not build profiles of people who have not written to us.
If you send us documents
A free report is a reading of a real situation, so at some point it needs the real papers. Depending on which report was asked for, we may ask for:
The identity page of a passport, its number and expiry date.
A current visa or residence card, and the most recent entry stamp.
A degree or professional certificate, and a written confirmation of experience.
A health certificate or a criminal record certificate, where a Vietnamese application requires one.
Documents showing where investment funds come from.
An existing lease, company registration, or an agreement already signed with someone else.
Four things hold true for all of them.
We ask only after a report has been requested, and we say what each document is for before asking for it.
Nothing is compulsory. Send what you have. Where something is missing, the report says plainly what could not be checked and why, rather than filling the gap with a guess.
Nothing is filed, applied for, submitted or paid on your behalf without your written authorisation. A copy sent to us for a report goes nowhere else.
No original passport is held in this office. Where an authority requires an original, we tell you first, and you either submit it in person or authorise us in writing to do it — against a signed receipt naming an agreed return date.
On which channel to use: documents can be sent by email, or through the messaging channel you are already using, whichever you prefer. Where they are sent through a messaging service, a copy also stays in that conversation on the platform's systems, which is worth knowing before choosing. Anyone who would rather that did not happen is welcome to use email instead, and it is no trouble.
What we never ask for
We do not ask for passwords or account logins, and no member of our team will ever request one.
We do not ask for payment card or bank card details in a message thread. Fees, where any arise, are invoiced.
We do not ask about a person's race, religion or political opinions, and we do not ask for details of their private life.
Where a health certificate or a criminal record certificate is needed, it is needed because a Vietnamese application requires it — not because we have any interest in its contents. It is read for that purpose and used for nothing else.
Why do we collect it, and how is it used?
For five purposes:
To prepare and send the free report or document a person has asked for.
To answer the question that was asked, and to carry on that conversation.
To keep a record of what was said, so that a person does not have to explain the same situation twice, and so that a matter can be picked up again later.
To tell a person about services of ours related to what they asked about, including through advertising on the platforms they contacted us on. Section 9 explains this and how to stop it.
To meet obligations that applicable Vietnamese law places on a business of this kind.
It is not used for anything outside this list, and it is not sold.
Is your information shared?
It is not sold, rented, or exchanged. It is not passed to any employer, school, agency, landlord or other business for their own use or marketing.
It leaves us in three situations only:
Where a step the person has asked for in writing requires it — for example a notary, a sworn translator, or the office receiving an application.
Where a service provider operates part of the systems we use to store records or send messages, in which case they act on our instructions and are bound to keep the information confidential.
Where applicable law requires disclosure.
We receive no commission, referral fee or other payment from any third party for introducing a person to them, and we pay none. Nothing in a report or a reply is shaped by who else stands to be paid.
How long is it kept?
Where a free report is prepared and the person does not go on to engage us for paid work, the file is kept for twelve months from the day the report is sent, and is then deleted.
Twelve months rather than forever, because a file that is no longer working for anyone is only a risk. Twelve months rather than immediately, because questions of this kind tend to come back around, and someone returning after six months should not have to send everything again.
Where a person does engage us, the file is kept for as long as the matter requires and for any period that applicable law requires records to be kept.
An enquiry that never becomes a report is kept only while it may still be useful to the person who made it.
A person may ask for their information to be deleted sooner than any of this, and we act on such a request unless a law requires the record to be kept.
Is information transferred outside Vietnam?
Messages sent through Facebook Messenger, Instagram Direct and WhatsApp are carried and stored on systems operated by the companies that run those services, which are located outside Vietnam. The same is true of any document attached to such a message. That is a consequence of choosing to write to us on those channels rather than a decision we make afterwards.
Where information is transferred outside Vietnam, it is done in the manner applicable Vietnamese law requires. A person who would rather their information stayed off those systems is welcome to say so, and we will continue by email instead.
Advertising and audiences
We advertise on Meta platforms, and we would rather name what that involves than leave it unmentioned.
The platform tells us, in aggregate, how many people saw or responded to an advertisement. We receive no personal information about people who only saw one and did not write to us.
Where a person has contacted us, their contact details may be used to include them in an audience on those platforms, so that our later advertisements are shown to them rather than to someone with no interest in the subject. This is the ordinary mechanism of advertising on those services.
It can be stopped. Write to us and we will remove you from those audiences, and we will not add you again. The platforms also have their own advertising settings, which work independently of anything we do.
Choosing not to reply to an advertisement has no consequence of any kind, and a person who has replied once is under no obligation to reply again.
What can you ask us to do?
At any time, and without giving a reason, a person may ask us to:
Tell them what information about them we hold, and where it came from.
Correct anything that is wrong or out of date.
Delete what we hold.
Stop using their information for a particular purpose, including advertising.
Withdraw a consent previously given, which takes effect from the moment it is withdrawn rather than retrospectively.
Requests are answered within the period applicable law allows, and there is no charge for a reasonable request. If a request cannot be met in full, the reason is given in writing.
A person who is not satisfied with how a request was handled may also complain to the competent authority in Vietnam.
How do we respond to requests from authorities?
Information is provided to a Vietnamese authority where applicable law requires it, and to the extent it requires.
We do not volunteer information about a person to any authority, employer, school or other party for their convenience, and we do not respond to informal requests that have no legal basis.
Where we are permitted to tell a person that a request concerning them has been made, we do.
How is your information protected?
A file passes through three defined roles: the person who takes in the enquiry, the person who analyses it and writes the report, and the person who reviews the report before it is sent. Nobody outside those roles has a reason to open it, and access is limited accordingly.
Files are held under a reference code rather than under a person's name wherever the work allows, so that a record on a screen does not identify anyone at a glance.
Everyone who works on a matter is bound by an obligation of confidentiality that continues after the matter has closed.
No system is beyond failure. Where a security incident affects a person's information, they are told, together with what is known and what is being done about it, within the period applicable law requires.
Children
Our services are for adults. Our advertisements are not directed to children and we do not knowingly collect information from them.
Where a matter concerns a family, any information about a child is provided by a parent or guardian and used only for that matter.
How will you know if this Policy changes?
The date at the top of this Policy shows when it was last changed. A revised Policy replaces the previous one from the date shown on it.
Where a change materially affects how information already given to us is handled, it is announced on the channels through which that information was given, rather than only posted here.
Legal framework
This Policy is written to be consistent with the law of Vietnam applicable to the protection of personal data, cyber security, network information security, electronic transactions and the protection of consumers, together with the platform rules of the services through which we advertise and communicate.
Where the law of the place a person is in gives them greater rights than this Policy describes, that law applies to them.
This Policy is a statement of how we work. It is general information for the people who write to us, and it is not legal advice on any individual situation.
How to contact us
Questions about this Policy, and any of the requests described above, can be sent to:
LotusGuard Vietnam Advisory — Ho Chi Minh City, Vietnam.