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ISHCMC - American Academy's Privacy & Cookie Policies
GENERAL PRIVACY NOTICE

1. INTRODUCTION
1.1 We are committed to protecting and respecting your privacy. ISHCMC - American Academy is an independent school which is part of the Cognita global schools group. In this privacy notice, references to "we", "us", "our" is a reference to AAVN.
1.2 This privacy notice deals with any personal data we process which is not covered in our parent and pupil privacy notices. It sets out the basis on which any personal data we collect from you is handled by us in the course of our relationship with you. For example, this notice applies to you if you are a potential recruit, next of kin, supplier, or potential supplier, alumni, or prospective pupil or parent of a prospective pupil.
1.3 For prospective parents and pupils, please also see our parent and pupil privacy notices. These are also available on our website.
1.4 This privacy notice is intended to inform you about collection, processing and utilization of your personal data. By accessing our website and providing us with any of your personal data, you consent us to use your personal data in compliance with this privacy notice.
1.5 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1.6 If you are reading this privacy notice online, we recommend that you print and retain a copy for future reference.

2. INFORMATION WE COLLECT ABOUT YOU
Information you give us

2.1 You may give us personal data about you, in a number of ways; these include:
2.1.1 Using, visiting, or interacting with our website (such as filling out forms or registering on our website);
2.1.2 Visiting our offices or schools;
2.1.3 During an interview or meeting;
2.1.4 Corresponding with us by phone, e-mail, or post;
2.1.5 Sending information directly to us, or providing information as requested by us (e.g., job application form, CV, or business card).

2.2 The information you give us may include the following:
2.2.1 Full name;
2.2.2 Photograph;
2.2.3 Marital status;
2.2.4 National registration identity card number;
2.2.5 Salary;
2.2.6 Employment history;
2.2.7 Contact details (e.g., home address, e-mail address, mobile/home/work phone number);
2.2.8 Financial information (e.g., payee details);
2.2.9 Passport details, nationality, and other immigration status information;
2.2.10 Previous educational records and achievements;
2.2.11 Information received via safeguarding forms when visiting a site;
2.2.12 Information about your physical or mental health, or disability status, for health and safety purposes or fitness to work assessments;
2.2.13 Information about your race, national/ethnic origin, religious or philosophical beliefs, or sexual life/orientation for equal opportunity monitoring;
2.2.14 References (as an applicant or potential supplier).

Technical information we collect about you when you visit our website

2.3 With regard to each of your visits to our website we may automatically collect the following information:
2.3.1 Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
2.3.2 Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our number.
2.4 Our website may contain links to and from the websites of our partner networks, advertisers, suppliers, and affiliates. If you follow a link to any of these websites, please note that these websites are not covered by this notice and may have their own privacy notices. We do not accept any responsibility or liability for these notices. Please check these third-party notices before you submit any personal data to these websites.

Information we receive from other sources

2.5 We may be working closely with third parties (including, for example, recruitment agents, previous employers, medical practitioners, education authorities, business partners, payment and delivery services) and may receive information about you from them.
2.6 We may also use CCTV footage to ensure our sites are safe. We may receive information about you if you use any of the other websites we operate or the other services we provide.

3. COOKIES
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy which is made available on this policy.

4. CONTACT US
4.1 Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our Data Protection Officer at data.complianceVN@cognita.com or International School Ho Chi Minh City – American Academy, addressed at 16 Vo Truong Toan, An Phu, Thu Duc City, Ho Chi Minh City, Vietnam.

5. USES MADE OF THE INFORMATION
Information you give to us

5.1 We will use the information you give to us to pursue the following legitimate interests (as applicable to our relationship with you):
5.1.1 promote the objects and interest of our schools, ensure the most efficient management of the schools and ensure that the schools’ legal obligations are adhered to;
5.1.2 to store this information on our management information system/s;
5.1.3 to enforce our terms of use with you or any other contract we may have with you;
5.1.4 for the purposes of recruitment; and
5.1.5 to enable us to receive your services;
5.1.6 where you have attended one of our schools, to keep you up to date with key school news and upcoming events;
5.2 In order to pursue the legitimate interests referred to in paragraphs 5.1.1 and 5.1.6, we rely on software applications and other technology to process personal data about you. These include the school’s management information system and our HR and finance systems. The third parties we use to deliver these applications are carefully chosen and vetted by us to ensure that, among other things, your information is kept secure. For further information on the kind of technology we use, please contact our Data Protection Officer (see paragraph 4).
5.3 We will also use the information you give to us as is necessary to carry out our obligations arising from the contract (or potential contract) between you and us and to provide you with the information and services that you request from us or receive the services we request from you. For example, we may be recruiting you for a role at Cognita, or engaging you to supply us with services and will use personal data where necessary to recruit you or receive your services.
5.4 In addition, we may be required by law to do the following (which is not an exhaustive list):
5.4.1 keep an accounting record of payment;
5.4.2 keep records as may be prescribed by our administration and governance arrangements;
5.4.3 keep a record to evidence fair recruitment processes.
5.5 Inevitably, there will be an overlap between what we do that is necessary to (a) perform our contract with you, (b) carry out our legal obligations and (c) pursue a legitimate interest although we have tried our best to demarcate these as set out above. If you have any questions about these please contact our Data Protection Officer (see paragraph 4).


Information we collect about you from our website
5.6 We will use this information for the following legitimate interests:
5.6.1 to contact you if you have made an enquiry to one of our schools via our online enquiry form and/or to inform you about available places in the future;
5.6.2 to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
5.6.3 to improve our website to ensure that content is presented in the most effective manner, and your online experience is as effective and appropriate as possible, for you and for your computer;
5.6.4 as part of our efforts to keep our website safe and secure.

Information we receive from other sources
5.7 We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for one of the purposes set out above (depending on the types of information we receive). For example, we may receive a reference from a previous employer relating to you, which may impact a recruitment decision.

When we disclose information
5.8 In order to pursue one of the legitimate interests set out above, we may share your personal information with:
5.8.1 Asia Regional Head Office;
5.8.2 A member of the Cognita group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries;
5.8.3 local authorities such as education authorities (for example, the Department of Education and Training, and the Ministry of Education and Training), Labor Invalids-Social Affairs authorities or the police where we have reason to believe there are safeguarding concerns in respect of a child;
5.8.4 business partners, professional advisors, suppliers and sub-contractors for the performance of any contract we enter into with them or you, provided that those apply privacy standards equivalent to the level of protection here under.
5.9 Subject to paragraph 5.10 below, we may disclose your personal information to third parties if we are under duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce our contract (between us and you) and other agreements.

Where we need to get your consent
5.10 We will not market services to you or use your personal information for sending advertisements, product/service introductions and other commercial information (other than in accordance with paragraph 5.1.6 above) and not share, disclose or transfer your personal information to third parties without seeking of your prior consent (which is different from the consent as set forth in paragraph 1.4 above) and you have the right to choose to either permit or not permit our use of your personal information in such cases. Please contact data.complainceVN@cognita.com if you no longer wish to be contacted by us.

6. TRANSMISSION OF PERSONAL INFORMATION OUTSIDE VIETNAM
The data that we process about you may be transferred to, and stored at, a destination outside Vietnam. We try to limit this where possible, but it may be necessary where, for example, one of our suppliers has a data centre outside Vietnam. We will take all the steps that are reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice. We will also ensure that the appropriate legal safeguards are in place prior to the transfer, for example ensuring that any contract between us and the recipient of the information are oblige the supplier to adhere to a standard equivalent to the level of protection in accordance with applicable laws.

7. YOUR RIGHTS
7.1 Under the applicable laws, you have the following rights:
7.1.1 Right to correction. You have the right to have inaccurate personal data about you rectified and deleted..
7.1.2 Right to restriction. You have the right to obtain from us the restriction of processing where: (a) you contest the accuracy of the personal data we hold about you; (b) the personal data has been unlawfully processed; (c) we no longer need the personal data but they are required in limited circumstances; and (d) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 7.1.4 for more details).
7.1.3 Right to request transfer. In certain circumstances, you have the right to receive personal data from us in a structured, commonly used and machine-readable formatand the right to transmit it to a third-party organization.
7.1.4 Right to object. You have the right to raise an objection to any of our processing in paragraphs 5.1 and 5.2. Please tell us if you object to any type of processing that we do and we will work with you to address any concerns you may have.
7.1.5 Right to object to marketing or disclosure to third parties. If you do not want us to process your personal data for the purpose of marketing target, please tell us and we will ensure that we no longer do this.
7.1.6 Right to request access. You have the right to access personal data we hold about you.
7.1.7 To exercise any of your rights above, please contact us via ourData Compliance Officer or the address in paragraph 4 above.

8. HOW LONG WE KEEP PERSONAL INFORMATION
8.1 We will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data is processed.
8.2 We follow a data retention policy which determines how long we keep specific types of personal information for. For further information about the criteria, which we use to determine what periods we keep specific information, please contact our Data Compliance Officer (see paragraph 4).

9. USE OF OUR WEBSITE
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

10. CHANGES TO OUR PRIVACY NOTICE
Any changes we make to this privacy notice in the future will be posted on our website and, where possible and appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.


1. WHAT IS A COOKIE?

1.1 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, if you agree. Cookies contain information that is transferred to your computer's hard drive. To find out more about cookies, visit www.aboutcookies.org.

2. ABOUT OUR USE OF COOKIES
2.1 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
2.2 When you visit our website, we may automatically collect the following information:
2.2.1 technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and
2.2.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our number.

3. COOKIES WE USE AND WHY
3.1 Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make use of e-billing services.
3.2 Google Advertising cookies.Google Analytics' Display Advertiser features are enabled for the Google Analytics property this website is tagged with. This means that Google Analytics will drop additional cookies on your browser and collect data using Google's advertising cookies and identifiers, in addition to data collected through a standard Google Analytics implementation. For more information about Google's Advertising Cookies and how you can control advertising cookies visit Google Advertising Privacy FAQ and Google's advertising cookies.
3.3 Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences.
3.4 Marketing cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising around the web more relevant to you. We may also share this information with third parties for this purpose.
3.5 You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

4. WE HAVE NO CONTROL OVER THIRD PARTY COOKIES

4.1 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
4.2 Our website may also contain links to and from the websites of our partner networks, advertisers, suppliers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own cookie notices and privacy notices, and that we do not accept any responsibility or liability for these notices. Please check these notices before you submit any personal data to these websites.

5. HOW DO I CHANGE MY COOKIE SETTINGS?
Generally, browsers allow some control of most cookies through the browser settings. To find information relating to the browser you are using, please visit the browser developer's website. Below are links to some of the most common browsers:

6. WHAT HAPPENS IF YOU BLOCK COOKIES?
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access all or parts of our site, and your user experience may be seriously downgraded while browsing the site.

7. EXPIRY OF COOKIES
When we send a cookie, we instruct your browser to keep that cookie for a certain period of time. For example, we may instruct your browser to keep the cookie for the period you are on the website; this is known as a “session cookie.” You can override the cookie expiration periods set by us, or any other website, by changing your cookie settings. If you do not change your settings, then all cookies set by us will expire after 6 months. Default expiration settings will vary for third-party cookies.

8. CONTACT US
If you have any questions regarding this Cookie Notice please contact marketingaa@aavn.edu.vn.