PRIVACY POLICY (FIRST CONSULTING GROUP)
This Privacy Policy (“Policy”) describes how First Consulting Group collects, processes, stores, and protects the personal information of individuals when you access our website, social media platforms, or use our immigration consulting services.
This Policy governs the collection, processing, and storage of your personal information when you interact with our website, social media pages, or any services provided by First Consulting Group.
This Policy applies only to individual users. We encourage you to read it carefully and check our website or social media regularly for any updates. Your continued use of our services after changes are posted constitutes your acceptance of the updated Policy.
2.1. “User”
Means any individual who accesses, inquires about, registers for, or uses the products, services, or operations of First Consulting Group.
2.2. “Personal Information” or “Personal Data”
Means any information in the form of symbols, letters, numbers, images, sounds, or similar formats in an electronic environment that relates to or can be used to identify a specific individual. Personal data includes both basic personal data and sensitive personal data.
2.3. Basic Personal Information includes:
(a) Full name (including middle name), birth name, and any other names used;
(b) Date of birth; date of death or disappearance (if applicable);
(c) Gender;
(d) Place of birth, place of birth registration, permanent residence, temporary residence, current address, hometown, and contact address;
(e) Nationality;
(f) Individual’s photograph/image;
(g) Phone number, national ID number, personal identification number, passport number, driver’s license number, vehicle plate number, personal tax ID, social security number, or health insurance card number;
(h) Marital status;
(i) Family relationship information (parents, children);
(j) Bank account information and data reflecting online activities or browsing history;
(k) Any other information linked to or capable of identifying a specific individual that is not classified as sensitive personal data;
(l) Other data as prescribed by applicable law.
2.4. Sensitive Personal Information
Includes information that, if breached, would directly affect the lawful rights and interests of the individual, such as:
(a) Political opinions or religious beliefs;
(b) Health status and private life recorded in medical records (excluding blood type);
(c) Racial or ethnic origin;
(d) Inherited or acquired genetic characteristics;
(e) Physical attributes or unique biological characteristics;
(f) Sexual life or sexual orientation;
(g) Criminal records or offenses collected by law enforcement;
(h) Banking and financial information (account details, deposits, transactions, etc.);
(i) Location data obtained through positioning services;
(j) Other data designated by law as requiring enhanced protection.
2.5. “Personal Data Protection”
Means all activities aimed at preventing, detecting, stopping, and handling violations related to personal data in accordance with applicable law.
2.6. “Processing of Personal Data”
Means any operation performed on personal data, including collection, recording, analysis, verification, storage, modification, disclosure, combination, access, retrieval, withdrawal, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, or destruction of personal data.
2.7. “Third Party”
Means any organization or individual other than First Consulting Group and the User. Any undefined terms in this Policy shall be interpreted in accordance with applicable Vietnamese law and relevant U.S. privacy regulations.
3.1. First Consulting Group may process your personal information for the following purposes:
(a) Providing our products and services (including U.S. immigration consulting);
(b) Adjusting, updating, securing, and improving our products and services;
(c) Verifying your identity and ensuring the security of your personal information;
(d) Responding to your service requests and support needs;
(e) Notifying you of changes to policies, promotions, or our services;
(f) Conducting internal analytics, measuring performance, and improving service quality or conducting marketing communications;
(g) Preventing and combating fraud, identity theft, and other illegal activities;
(h) Establishing, exercising, or defending legal rights or claims of First Consulting Group, you, or any individual (including data exchange to prevent fraud or reduce credit risk);
(i) Complying with applicable laws, industry standards, and our internal policies;
(j) Any other purpose necessary for our business operations.
3.2. We will obtain your consent before using your personal information for any purpose other than those listed above, at the time of collection or before such processing begins, unless otherwise permitted by law.
4.1. We are committed to protecting your personal information to the highest standard in accordance with our internal policies and applicable law. Processing occurs only with your consent, unless otherwise required or permitted by law.
4.2. We do not use, transfer, provide, or share your personal information with any third party without your consent, except as required or permitted by law.
4.3. We comply with all other applicable data protection regulations.
4.4. We employ various information security technologies to protect your data from unauthorized use or disclosure. However, no security measure is 100% foolproof. We strive to protect your information to the best of our ability, but the following risks may still occur: (a) Hardware or software failures leading to data loss; (b) Security vulnerabilities or cyberattacks beyond our control; (c) User errors, such as sharing information carelessly or falling victim to phishing/scams.
4.5. You should secure your own electronic devices, lock or log out of your account when not in use, and avoid accessing suspicious websites or downloading untrusted applications.
To provide our services and respond to your requests, we may collect:
(a) Basic and sensitive personal information about you and your related family members;
(b) Technical data (device type, operating system, browser type, IP address, language settings, connection time, usage statistics, location data, etc.);
(c) Marketing data (advertising interests, cookies, clickstream data, browsing history, responses to direct marketing, and opt-out preferences).
6.1. Directly from You
(a) When you submit registration forms or any other forms related to our services;
(b) When you interact with our immigration consultants via phone, email, in-person meetings, or social media;
(c) When you use our website or social media pages;
(d) When you respond to communications from our team;
(e) When you voluntarily provide information or express interest in our services.
6.2. From Third Parties
(a) From third-party platforms when you interact with our content or advertisements (in accordance with their privacy policies);
(b) From payment service providers if you make electronic payments;
(c) From government authorities or public sources as required or permitted by law;
(d) From publicly available information (directories, advertisements, etc.).
We ensure all third-party data collection is lawful and that third parties comply with applicable data protection laws.
7.1. We may share or jointly process your personal information with:
(a) Our affiliates, branches, employees, and staff;
(b) Telecommunications providers (in cases of payment violations);
(c) Professional advisors (e.g., lawyers) as permitted by law;
(d) Courts or competent government authorities when required or permitted by law.
7.2. Sharing occurs only when necessary to fulfill the purposes in this Policy or as required by law. Recipients must comply with this Policy and applicable data protection laws. We make reasonable efforts to anonymize or encrypt data where possible, but we cannot eliminate all risks in force majeure situations.
7.3. Where other data processors are involved, we will notify you in advance as required.
9.1. Your Rights (subject to applicable law):
(a) Right to consent or withdraw consent to processing;
(b) Right to access, view, and request correction of your personal information;
(c) Right to withdraw consent (does not affect prior lawful processing);
(d) Right to request deletion of your personal information;
(e) Right to request restriction of processing (we will act within 72 hours where applicable);
(f) Right to request a copy of your personal information;
(g) Right to complain, report, or file lawsuits as permitted by law;
(h) Right to claim compensation for actual damages caused by violations;
(i) Other rights under applicable law.
9.2. Your Obligations
(a) Comply with applicable laws and our policies;
(b) Provide complete, accurate, and truthful information and promptly notify us of any changes;
(c) Cooperate with us or authorities on security issues;
(d) Protect your own data and promptly report any suspected breaches;
(e) Take responsibility for information you post or share online;
(f) Regularly review our policies and follow instructions regarding consent;
(g) Respect the privacy of others;
(h) Fulfill other obligations under applicable law.
First Consulting Group is committed to storing your personal information only when it is necessary for the purposes stated in this Privacy Policy. In certain cases, we may also need to retain your personal information for a specific period of time as required by law or for legitimate business purposes.
11.1 To fulfill the purposes of processing personal information outlined in this Privacy Policy, First Consulting Group may need to provide or share your personal information with relevant partners and third parties. These parties may be located in Vietnam or in the United States.
11.2 When transferring personal information outside of Vietnam, First Consulting Group will require the receiving parties to commit to ensuring the safety and security of your personal information. We are committed to complying with all applicable legal obligations and regulations regarding the cross-border transfer of personal data.
12.1 When you access or use our websites or online communication channels (collectively referred to as “online platforms”), First Consulting Group may place one or more cookies on your device. A “cookie” is a small file placed on your device when you visit an online platform. It records information about your device, browser, and, in some cases, your preferences and browsing habits.
First Consulting Group may use this information to recognize you when you return to our online platforms, to provide personalized services, to compile analytical data for better understanding the performance of our platforms, and to improve our websites and services. You can use your browser settings to delete or block cookies on your device. However, if you choose not to accept or block cookies from our online platforms, you may not be able to fully utilize all features of our websites and services.
12.2 First Consulting Group may process your personal information through cookie technology in accordance with this Privacy Policy. We may also use retargeting strategies to display advertisements to individuals who have previously visited our online channels.
12.3 To the extent that third parties embed content on our online platforms (for example, social media features), those third parties may collect your personal information (such as cookie data) if you choose to interact with their content or use their services.
13.1 You understand and agree that this Privacy Policy may be amended from time to time. Any changes will be notified to you through First Consulting Group’s communication channels before they take effect. The changes will become effective at the time we notify you. Your continued use of our services after being notified of any modifications or additions constitutes your acceptance of those changes.
13.2 You acknowledge and agree that this Privacy Policy also serves as our Notice of Personal Data Processing. It may be amended or supplemented periodically before First Consulting Group processes your personal data. Therefore, we are not required to provide any additional forms of notice regarding the processing of your personal data.
13.3 You commit to strictly complying with the provisions set forth in this Privacy Policy. For any matters not specifically addressed here, the parties will follow applicable laws and guidance from competent state authorities. If there are any changes or additions to the current Policy, First Consulting Group will provide specific notice to you.
13.4 You may encounter advertisements or other content on websites, applications, or devices that link to websites or services of our partners, advertisers, sponsors, or other third parties associated with First Consulting Group. We do not control the content or links appearing on third-party websites or services and are not legally responsible for the activities or information provided by those third-party sites or services. These online platforms and services may have their own separate privacy policies and terms of use.
13.5 These terms are established on the basis of good faith between First Consulting Group and you. In the event of any dispute, the parties will first attempt to resolve it through good-faith negotiation and mediation. If mediation fails, the dispute will be referred to the competent state authority for resolution in accordance with applicable law.