Privacy Policy

Last Updated: July 1, 2026

1. Introduction

We collect and process personal data to provide recruitment, executive search, talent mapping, employer of record (EOR), payroll outsourcing, business relationship management, and other related professional services. Recognizing the critical importance of this information, we are fully committed to safeguarding your online privacy. Our newly updated privacy policy outlines precisely how we manage, protect, and utilize your data.

Pegasi Recruitment Co., Ltd. with Enterprise Registration Number: 0314967944, Address: Room 804, 8th floor, Centec Tower, 72-74 Nguyen Thi Minh Khai Street, Xuan Hoa Ward, Ho Chi Minh City, Vietnam, email recruit@pegasi.com.vn and Tel: +84 28 3622 8666 ("Pegasi", "we", "our", or "us") respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, store, protect and otherwise process your personal data when you interact with us, including through our website, recruitment services, employer of record (EOR), payroll outsourcing services, talent mapping services, marketing activities, events and any other business relationship.

This Privacy Policy is prepared in accordance with the Law on Personal Data Protection No. 91/2025/QH15 and other applicable laws of Vietnam.

2. Scope

To deliver world-class headhunting and professional recruitment consultancy services, this Privacy Policy governs how Pegasi collects, handles, and secures the data of specific target groups. Depending on the operational context, Pegasi acts as a Data Controller or a Data Controller-cum-Processor under Law No. 91/2025/QH15.

This Privacy Policy outlines how Pegasi processes and safeguards the personal data of Job applications, Candidates, Employees of clients, Client representatives, Prospective clients, Business partners, Vendors, Website visitors and Event participants (Collectively referred to as “you” or “your”).

3. Purposes for Collecting, Using, or Disclosing Personal Data

We process personal data to:

  • Recruit candidates
  • Match candidates with suitable positions
  • Verify candidate qualifications
  • Arrange interviews
  • Contact candidates
  • Provide recruitment consulting
  • Provide Employer of Record (EOR) services
  • Provide Payroll Outsourcing services
  • Perform Talent Mapping
  • Respond to enquiries
  • Improve our services
  • Conduct surveys
  • Organize events
  • Send recruitment opportunities
  • Send newsletters or marketing communications where permitted
  • Comply with legal obligations
  • Protect our legal rights
  • Resolve disputes

4. Personal Data We Collect

Depending on the relationship with you, we may collect:

  • Identity Information: Full name, Date of birth, Gender (where appropriate or required), Nationality, Photograph (where voluntarily provided or required for recruitment), National ID card, Citizen ID card, Passport or other government-issued identification (where required by law or necessary for employment-related purposes)
  • Contact Information: Email, Phone number, Address, LinkedIn profile, Other professional networking account
  • Recruitment Information: Curriculum Vitae (CV)/ Resume, Employment history, Educational background, Professional qualifications, Skills and competencies, Professional licenses or certifications, Salary expectations, Employment preferences
  • Interview notes and assessments, Reference check information (where authorized)
  • Employment Information where Pegasi provides EOR or Payroll services: Employment contract, Tax information, Social insurance information, Payroll information, Banking information, Attendance records
  • Website Information: IP address, Browser type, Device information, Cookies, Website usage information, Log files
  • Communication Information: Emails, Chat messages, Phone call notes, Meeting records, Customer service enquiries
  • Sensitive personal data: Where required for recruitment, employment administration, legal compliance, or other legitimate business purposes, Pegasi may process certain categories of sensitive personal data in accordance with applicable laws, including:
    • National identification number or passport number
    • Tax identification number
    • Bank account information
    • Social insurance information
    • Health information where required for employment administration or employee benefits
    • Biometric information where required by applicable law or with your consent
    • Criminal record or background screening results where legally permitted and relevant to the position
    • Other categories of sensitive personal data as defined under applicable laws
    • Pegasi will never process sensitive information without your separate, explicit, and written or digital consent
    • Pegasi will only process sensitive personal data where permitted by law and will implement appropriate technical and organizational measures to protect such data

5. How We Collect Personal Data

We may collect personal data:

  • Directly from you
  • Through our website
  • Through job applications
  • Through LinkedIn or other professional networking platforms
  • Through referrals
  • Through recruitment events
  • Through our clients
  • Through publicly available professional sources
  • Through legally authorized third parties

6. Providing Your Personal Data

In many instances, providing your personal data is a contractual or statutory requirement necessary for us to initiate or maintain our professional collaboration. If you choose to withhold the requested personal data, Pegasi may be unable to effectively render our work-finding, recruitment, or commercial services. Consequently, this may result in our inability to consider your candidacy for prospective roles, process your job applications, or fulfill our obligations under our service agreements.

Pegasi processes personal data based on:

  • The consent of the data subject
  • Recruitment and employment-related activities requested by the data subject
  • Contractual obligations
  • Legal obligations
  • Other lawful bases permitted under the Law on Personal Data Protection and other applicable laws

7. Cookies, Tracking, and Email Synchronization

We use cookies, web beacons, and technical identifiers to improve performance, save preferences, and coordinate communication histories.

  • Functional Cookies: Essential for keeping you logged into your applicant portal and securing your session.
  • Analytics & Performance: We utilize industry-standard tracking tools (such as Google Analytics) to generate aggregated traffic reports. You may adjust your browser preferences to reject cookies, though some platform features may cease to function correctly.
  • Email Communications: Pegasi may use standard email and communication technologies to facilitate recruitment-related communications, interview scheduling, candidate engagement, and the maintenance of communication records in connection with our recruitment and business activities.

By continuing to use our website, you acknowledge that cookies may be used as described in this Privacy Policy. You may modify your browser settings to control or disable cookies; however, certain website functionalities may not operate properly as a result.

8. How We Share and Disclose Data

Pegasi does not sell, rent, or trade your personal data to third parties for marketing purposes. Your personal data is strictly shared on a need-to-know basis (within or outside Vietnam) and in accordance with applicable data protection laws under the following conditions:

  • Clients: Where you apply for a position or express interest in career opportunities, Pegasi may disclose your personal data, including your CV/resume, professional profile, qualifications, interview feedback, and other relevant recruitment information, to our clients or prospective employers for recruitment and hiring purposes. Where required by applicable law or our recruitment process, we will obtain your consent before submitting your profile to a client.
  • Candidates and Job Applicants: Where necessary for recruitment activities, Pegasi may disclose limited personal data of our clients' representatives (such as recruiters, hiring managers, interviewers, or other authorized contacts) to candidates for purposes including interview scheduling, recruitment communications, onboarding coordination, or other employment-related processes. Pegasi will only disclose information that is necessary for these purposes.
  • Affiliated Entities (if any): Personal data may be shared with Pegasi's affiliated entities solely for recruitment operations, internal administration, compliance, and service delivery purposes.
  • Service Providers & Data Processors: Pegasi may engage third-party service providers to support recruitment and business operations, including applicant tracking systems, cloud hosting services, email and communication platforms, IT support providers, CRM, Google Workspace, Payroll partners, EOR partners, and background verification providers (where applicable). Such providers are required to process personal data only for authorized purposes and in accordance with applicable contractual and legal requirements.
  • Legal Compliance & Protection: We will disclose personal data to judicial bodies, regulatory authorities, or law enforcement agencies if required by law, court order, or subpoena. This includes disclosures necessary to protect the rights, property, or safety of Pegasi, our users, or to investigate and prevent fraudulent platform activities.
  • Corporate Restructuring & Business Transitions: In the event of a merger, acquisition, asset sale, or corporate restructuring, user databases may be transferred to the acquiring or successor entity. Any such transfer will be conducted under strict confidentiality guidelines and subject to the commitments outlined in this Privacy Policy.

9. Data Security and Breach Notification

The integrity and security of your technical and personal data are paramount. We deploy rigorous physical, administrative, and electronic safeguards, including industry-standard encryption protocols (SSL/TLS), firewalls, and strict access controls restricted solely to authorized personnel on a need-to-know basis.

  • In the event of a personal data incident, Pegasi will take reasonable measures to investigate, contain, mitigate, and remediate the incident. Where required by applicable laws, Pegasi will notify competent authorities and affected individuals in accordance with legal requirements.
  • While Pegasi applies reasonable technical and organizational measures to protect personal data, no method of electronic transmission, storage, or processing can be guaranteed to be completely secure. Potential risks may include unauthorized access, data loss, cyberattacks, technical failures, or other events beyond Pegasi's reasonable control.

10. Data Retention Lifespan

We will retain personal data collected and processed in accordance with the purposes set out in Section Purposes of Personal Data Processing of this Privacy Policy for as long as necessary to fulfill such purposes. Unless otherwise required or permitted by applicable laws, we may retain personal data until the data subject requests the deletion of such personal data.

11. Your Statutory Rights and Choices

Subject to applicable laws, data subjects may exercise certain rights regarding their personal data. You may exercise any of the following statutory rights at any time by contacting our data protection desk:

  • Right to be informed
  • Right to consent
  • Right to access and copy
  • Right to withdraw consent
  • Right to data deletion
  • Right to restriction of processing
  • Right to data portability
  • Right to object to processing
  • Right to complain, denounce, or litigate
  • Right to claim damages
  • Right to self-defense

Verification & Processing: To submit a formal data privacy request, please email us directly at recruit@pegasi.com.vn with the subject line "Data Privacy Request". To prevent unauthorized data disclosure, Pegasi reserves the right to verify your identity through secure validation methods before processing your request. Verified requests will be fulfilled within the legal timelines prescribed by applicable local laws.

12. Changes to this Privacy Policy

Pegasi reserves the right to amend, update, or modify this Privacy Policy from time to time to reflect changes in applicable laws, regulatory requirements, business operations, technologies, or personal data processing activities. Any updated version of this Privacy Policy will be published on Pegasi's website. The "Last Updated" date at the beginning of this Privacy Policy will indicate the effective date of the latest revision. Where required by applicable laws, Pegasi will take reasonable steps to notify affected individuals of material changes to this Privacy Policy.

13. Governing Law and Dispute Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the Socialist Republic of Vietnam.

Any dispute arising out of or relating to this Privacy Policy shall be subject to the jurisdiction of the competent courts or authorities of Vietnam unless otherwise required by applicable law.

14. Personal Data Protection Contact

For technical queries regarding this policy, security concerns, regulatory compliance verification, or to exercise your data subject rights, please contact our designated Data Protection desk:

  • Pegasi Data Protection Team Email: recruit@pegasi.com.vn (Attn: Pegasi Personal Data Protection Contact)
  • Primary Office: Ho Chi Minh City, Vietnam