Personal Data Protection Policy

1. Scope

This policy applies to personal data processed when you visit our website, request a consultation, take a practice test or use an online tool, enrol, pay, subscribe to our newsletter, attend an event, apply for a job, or contact us by phone, email, Zalo, social media or the chat box on our website.

It follows Vietnamese personal data protection law, including Decree 330/2026/ND-CP, in force from 19 August 2026.

2. Personal data we may collect

• Identity: full name, date of birth, gender; ID or passport number only where genuinely needed for a contract or payment procedure.
• Contact: phone number, email address, address; parent or guardian details where the student is a minor.
• Study & transactions: courses of interest, entry level, previous and target scores, results of practice tests taken on our website, enrolment and payment history, and records of your questions or complaints.
• Technical data: IP address, browser and device type, pages viewed — for operation, security and statistics.

We collect only what fits the purpose we have notified, to the extent needed. You do not have to fill in every field — anything not marked required is optional.

3. Why we process your data

• To contact you about the request you sent: call you back, advise on a study plan, arrange a placement test, send the result of the practice test you just took.
• To deliver our services: enrolment, student records, class and timetable arrangements, materials and notifications, invoicing, payment confirmation and support during your course.
• To operate and comply: system security, fraud prevention, complaint handling, accounting, tax and other legal obligations.
• To send marketing information (offers, class schedules, newsletters) — ONLY where you have given separate consent for that purpose.

We do not use your data for purposes beyond those notified. If a new purpose arises, we will inform you and seek fresh consent.

4. How we obtain your consent

Every form on our website that collects personal data states the purpose before you submit, and carries a REQUIRED consent box that is never pre-ticked. If you do not tick it, the form is not submitted — we never treat silence, or the act of clicking a button, as consent.

The box for marketing messages is SEPARATE and always optional. Leaving it unticked does not stop you submitting the form or receiving advice — we do not make service conditional on accepting marketing.

For the chat box on our website: the details you choose to send (name, phone number) are used to contact you with advice, and this is stated inside the chat box itself.

For email newsletters: after you sign up we send a confirmation email and only begin sending once you confirm. Every email carries an unsubscribe link.

Each consent is recorded as evidence: the exact wording you were shown, its version, the time, the page it came from, and the IP address. This lets us demonstrate that processing was lawful, and lets you verify it if you ever ask.

5. How we collect data

• When you complete a form on our website: consultation request, appointment booking, deposit, tuition voucher purchase, referral, partnership enquiry, job application.
• When you use a free online tool (practice test, score estimator, study planner) and leave your details to receive the result.
• When you write in the chat box, call our hotline, send an email, or reach us on Zalo and social media.
• When you enrol, pay, or take part in an event, survey or trial programme we run.
• Automatically when you browse the website, limited to technical data needed for operation, security and statistics.

6. Cookies, technical data & analytics

Our website may use cookies, measurement tools and system logs to make the site work, remember your preferences, improve performance, maintain security and analyse how our services are used.

You can set your browser to refuse or manage cookies. Disabling some cookies may affect your experience or certain features.

7. Who may access your data

Clever Academy does NOT sell your personal data. We share it only as far as necessary, in line with the purpose notified to you, or where a competent authority lawfully requires it.

• Authorised internal staff and departments — services, customer care, student records, finance, IT and complaint handling.
• Infrastructure and technical service providers we engage — servers and content delivery, database, file storage, email delivery, payment gateways, website analytics, messaging platforms, and the AI assistant behind our advisory chat box.
• Competent state authorities — where we have a reporting duty or receive a lawful request.
• A transferee in a corporate transaction — merger, acquisition or restructuring, under equivalent confidentiality obligations.

Some infrastructure providers host servers outside Vietnam, so data may be stored or processed abroad. For every party processing data on our behalf we apply contractual controls so the data is used only for the stated purpose, properly protected, and not used for anything else.

8. How long we keep your data

We keep personal data for as long as the purpose requires: performing the contract and supporting students, resolving disputes, meeting accounting and tax requirements, and protecting the lawful rights of the parties.

When data is no longer needed, or when you make a valid request, we delete, destroy, anonymise or stop processing it, according to the nature of the data and any statutory retention duty.

CONSENT RECORDS are an exception: we keep them even after you withdraw consent, including the record of the withdrawal itself. They are the evidence that processing was justified at the time — deleting them would leave both sides with nothing to check against.

9. How we protect your data

We apply appropriate technical and organisational measures: role-based access control, encryption in transit, audit logs on sensitive data, backups, and keeping the number of people who can reach personal data to the minimum the work requires.

No system is perfectly secure. If an incident affects personal data, we will handle it and notify as the law requires.

10. Your rights

• To be informed and to access: know what data of yours we process and why, and request a copy.
• To correct: ask us to fix data that is inaccurate or incomplete.
• To withdraw consent: at any time, as easily as you gave it. Withdrawal does not affect the lawfulness of processing before it.
• To request deletion or restriction, except data we must retain by law.
• To object to processing, in particular for marketing.
• To complain to Clever Academy or to a competent state authority.

11. How to exercise your rights

Email info@cleveracademy.vn or call 097 586 1994. To protect you, we may need to verify your identity before releasing or changing data.

If you only want to stop marketing emails, use the unsubscribe link at the bottom of any email we send — it takes effect immediately and you do not need to contact anyone.

You may also ask what consent records we hold against your phone number or email address; we will look them up and answer a valid request.

12. Complaints

Please send any concern about our handling of personal data to info@cleveracademy.vn or call 097 586 1994. We receive, respond and resolve within the timeframes set out in our General Trading Conditions.

If you are not satisfied with our handling, you may complain to a competent state authority as provided by law.

13. Data controller

• Company: Clever Academy Joint Stock Company
• Business registration / Tax code: 0106793422
• Registered office: No. 139 Nguyen Thai Hoc Street, O Cho Dua Ward, Hanoi City, Vietnam
• Hanoi Campus: 3rd Floor, Viet Tower, 1 Thai Ha Street, Dong Da District, Hanoi
• Saigon Campus: Unit 1681, 16th Floor, Bitexco Financial Tower, 2 Hai Trieu Street, Ben Nghe Ward, District 1, Ho Chi Minh City
• Phone: 097 586 1994
• Email: info@cleveracademy.vn

14. Changes to this policy

We may update this policy to reflect changes in law, our systems, products, services or data-processing practices. The updated version is published on this website and takes effect from publication unless we state otherwise.

Where a significant change could materially affect your rights or interests, we will consider giving notice in a manner appropriate to the change and to the service concerned.