Privacy Policy for Personal Data Protection

This Privacy Policy for Personal Data Protection (hereinafter referred to as the Privacy Policy or the Policy) applies to the Wellspring International Bilingual School System (hereinafter referred to as WS).

By registering to explore, registering to use, using the Products and Services, entering into contracts, and/or providing Personal Data to WS on any platform and/or in any form that enables WS to Process Personal Data, the Data Subject acknowledges that they have read, fully understood, and unconditionally accepted all contents of this Policy and any changes (if any) from time to time.

1. DEFINITIONS

Terms used in this Policy shall be interpreted as follows:

• 1.1 Personal Data: information in the form of symbols, letters, numbers, images, sounds, or similar formats in an electronic environment that is associated with a specific individual or that helps identify a specific individual. Personal Data includes Basic Personal Data and Sensitive Personal Data.
• 1.2 Processing of Personal Data (Processing): one or multiple operations performed on Personal Data, such as collection, recording, analysis, verification, storage, modification, disclosure, combination, access, retrieval, recall, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction, or other related actions.
• 1.3 WS Products, Services, and Utilities (collectively, Products and Services):products, services, and utilities of WS and/or those of third parties with whom WS collaborates.
• 1.4 WS Institutions: schools managed by WS at certain points in time.
• 1.5 Data Subject: the individual to whom Personal Data relates, including all parents, students, guardians of students who register to explore or are using Products and Services, users of WS\s digital platforms, employees, collaborators, prospective candidates, shareholders, and other individuals related to or arising from the use or provision of products, services, employment relationships, or other legal relationships with WS.
• 1.6 Personal Data Provider (Provider): individuals or organizations acting on behalf of, or with the consent of, a Data Subject to provide that Data Subject\s Personal Data to WS.

2. PERSONAL DATA PROCESSED

To enable WS to Process for the purposes set out in Section 3 of this Policy and to comply with other applicable legal regulations governing WS\s operations, WS will need to collect and Process the following categories of the Data Subject\s Personal Data, including Basic Personal Data and Sensitive Personal Data:

• Given name(s), middle name, and birth name; other names/aliases (if any)
• Date, month, and year of birth; date, month, and year of death or disappearance
• Gender
• Place of birth, place of birth registration, place of permanent residence, temporary residence, current residence, place of origin, and contact addresses
• Nationality
• Images of the individual; information obtained from security systems, including audio and video recordings
• Telephone number, identity card number, personal identification number, passport number, driver\s license number, vehicle license plate number, personal tax identification number, social insurance number, health insurance card number
• Marital status
• Information on family relationships (parents, spouse, children)
• Email address
• Handwriting and signature, including electronic signature
• Information on educational and employment history; academic qualifications, diplomas, and certificates
• Payment information, such as bank account number, credit card number
• Account information, such as user ID and password
• Technical and web data such as Internet Protocol (IP) address, login data, browser type and version

3. PURPOSES OF COLLECTION, USE, AND DISCLOSURE OF PERSONAL DATA

Personal Data may be used by WS, or by a Data Processor, or by an Authorized Third Party to Process Personal Data for one or more of the following purposes:

• Verifying the identity of the Data Subject and managing online accounts
• Providing Products and Services to the Data Subject
• Verifying and carrying out online financial transactions relating to payment
• Contacting the Data Subject to handle and respond to queries, feedback, complaints, or disputes
• Contacting the Data Subject to exchange information and transaction content
• Notifying the Data Subject of Products and Services provided by WS or its partner companies
• Improving WS Platforms and the Products and Services
• Conducting market research on demographics, advertising or purchasing preferences
• Verifying candidate eligibility; evaluating profiles, documents, and materials for recruitment
• Enforcing the Data Subject\s requests and performing obligations under contracts
• Operating internal activities, business activities, and internal risk management
• Complying with laws and international treaties

4. METHODS OF PROCESSING PERSONAL DATA

Depending on the purposes of Processing, WS or WS\s Data Processor or an Authorized Third Party may apply appropriate methods of Processing, including but not limited to automated methods, manual methods, or other methods in compliance with applicable laws and WS\s policies from time to time.

The Data Subject\s Personal Data will be stored and Processed in whole or in part in Vietnam and/or abroad, including storage solutions on cloud computing. Personal Data shall be stored for the period necessary to fulfill the Purposes as agreed with the Data Subject in this Policy.

5. RIGHTS AND OBLIGATIONS OF THE DATA SUBJECT

5.1 Rights of the Data Subject

The Data Subject shall be respected by WS, and WS shall endeavor to protect the Data Subject\s rights, including:

• Right to be informed
• Right to consent
• Right of access (including to view, correct, or request correction of Personal Data)
• Right to withdraw consent
• Right to erasure
• Right to restriction of Processing
• Right to data provision (data portability)
• Right to object to Processing
• Right to complain, denounce, and initiate legal proceedings
• Right to claim compensation for damages
• Right to self-protection

5.2 Obligations of the Data Subject

• Protect, control, and Process their own Personal Data
• Respect and protect the Personal Data of others
• Provide complete and accurate Personal Data and documents for verification
• Notify timely corrections and updates to all changes or errors concerning Personal Data
• Participate in disseminating and popularizing skills in Personal Data protection
• Comply with legal provisions on Personal Data protection

6. DURATION OF PERSONAL DATA PROCESSING

Start time: WS will commence Processing Personal Data upon receiving Personal Data with the Data Subject\s consent relating to the Processing of Personal Data in accordance with this Policy.

End time: WS will cease Processing Personal Data upon the Data Subject\s written request, upon termination of legal arrangements, upon completion of Processing purposes consented to by the Data Subject, or as otherwise prescribed by law.

7. POSSIBLE UNWANTED CONSEQUENCES OR DAMAGES

Processing Personal Data inherently carries risks of data leakage or inappropriate data Processing. WS recognizes the importance and responsibility of protecting Personal Data, commits to applying appropriate protective measures under current laws, and regularly reviews and updates the most optimal technical measures to ensure safety in Processing Personal Data.

8. CHANGES TO THE PRIVACY POLICY

WS reserves the right to change and update this Policy at any time, provided such updates and changes are not contrary to current laws. Such changes and updates will be notified to all Data Subjects via email, text message (SMS), or telephone.

9. CONTACT INFORMATION

If the Data Subject has any questions regarding this Policy or any other inquiries relating to how WS manages, protects, and/or Processes the Data Subject\s Personal Data, please contact WS via the following details: