Privacy Policy
for DOM Partners
Introduction
DOM Partners (“DOM Partners”, “we”, “us”, or “our”) is committed to protecting your privacy and handling your personal data openly and lawfully. This Privacy Policy explains what personal data we collect, how we use it, who we share it with, how long we keep it, and the rights you have over it.
This policy applies to our website [dompartners.co] (the “Site”) and to any services, communications, and business dealings where we act as a controller of your personal data.
We operate internationally. We are based in Vietnam and provide services to clients in the United Kingdom, the European Union, the United States, and other regions. This means several data protection laws may apply to you depending on where you are located, and this policy is written to respect all of them.
By using our Site or contacting us, you acknowledge that you have read and understood this Privacy Policy.
Who we are (Data Controller)
For the purposes of applicable data protection law, the controller of your personal data is:
DOM Partners, 19 Ngoc Khanh, Ba Dinh, Hanoi, Vietnam.
Email: [privacy@dompartners.co] General contact: [info@dompartners.co]
[If you appoint an EU or UK representative or a Data Protection Officer, add their details here. A DPO is not mandatory for a business of your size unless your core activities involve large-scale or sensitive data processing – but an EU/UK representative may be required under Article 27 GDPR if you offer services to, or monitor, individuals in the EU/UK.
The personal data we collect
We collect personal data in the following ways:
a) Information you give us directly. When you fill in a contact or enquiry form, book a call, email us, or otherwise communicate with us, we may collect your name, business name, job title, email address, telephone number, country, and the contents of your message.
b) Information we collect automatically. When you visit our Site, we may automatically collect technical data such as your IP address, browser type and version, device information, operating system, referring website, the pages you view, and the dates and times of your visits. We collect this through cookies and similar technologies (see Section 8).
c) Information from third parties. We may receive limited information about you from analytics providers, advertising platforms, or business contact sources where you have interacted with our content or where such data is lawfully available.
We do not intentionally collect special category / sensitive personal data (such as health, race, religion, or political views) through our Site. Please do not send us such information unless it is necessary and we have agreed how it will be handled.
How we use your personal data, and our legal bases
We use your personal data for the following purposes. Where GDPR or UK GDPR applies, we rely on the legal bases shown.
| Purpose | Legal basis (GDPR / UK GDPR) |
|---|---|
| To respond to your enquiries and communicate with you | Legitimate interests; steps prior to entering a contract |
| To provide, manage and deliver our services | Performance of a contract |
| To operate, maintain and improve our Site | Legitimate interests |
| To send business updates or marketing (where permitted) | Consent, or legitimate interests where lawful |
| To analyse Site usage and measure performance | Consent (for non-essential cookies); legitimate interests |
| To keep records and comply with legal, tax and accounting obligations | Legal obligation |
| To protect our Site, prevent fraud, and ensure security | Legitimate interests |
| To establish, exercise or defend legal claims | Legitimate interests; legal obligation |
Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms. You may ask us for more information about this assessment.
Where we rely on consent (for example, certain marketing or non-essential cookies), you may withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.
Marketing communications
If we send you marketing communications, we will only do so where we are permitted to. You can opt out at any time by using the unsubscribe link in our emails or by contacting us at [privacy@dompartners.co]. Opting out of marketing does not stop service-related or transactional messages that we need to send you.
Who we share your personal data with
We do not sell your personal data. We may share it with:
- Service providers and processors who help us run our business — for example website hosting, email, cloud storage, analytics, and customer-communication tools. These providers act on our instructions and are bound by confidentiality and data protection obligations.
- Our professional advisers — such as lawyers, accountants, and auditors — where necessary.
- Authorities, regulators, or third parties where required by law, to comply with legal process, or to protect our rights, safety, or property.
- A successor entity in the event of a merger, acquisition, or reorganisation of our business, subject to this policy.
International data transfers
We are based in Vietnam, and our clients and their data may originate from the United Kingdom, the European Union, the United States, and elsewhere. This means your personal data may be transferred to, stored in, or accessed from countries other than your own, including Vietnam.
Vietnam is not currently recognised by the UK or the European Commission as providing an “adequate” level of data protection. Where we transfer personal data from the UK or EU to Vietnam or to any other country without an adequacy decision, we put appropriate safeguards in place, which may include:
- Standard Contractual Clauses (SCCs) approved by the European Commission, and/or the UK International Data Transfer Agreement (IDTA) or UK Addendum; and
- additional technical and organisational measures where needed.
We also comply with Vietnam’s Personal Data Protection Decree (Decree 13/2023/ND-CP), including its requirements relating to the cross-border transfer of personal data where applicable.
You may contact us at [privacy@dompartners.co] to request more information about the safeguards we use.
Cookies and similar technologies
Our Site uses cookies and similar technologies to function, to remember your preferences, and to understand how the Site is used.
- Strictly necessary cookies are required for the Site to work and cannot be switched off.
- Analytics/performance cookies help us understand how visitors use the Site.
- Functionality and marketing cookies may be used to improve your experience or measure campaigns.
Where required by law, we will ask for your consent before setting non-essential cookies, and you can manage your preferences through our cookie banner or your browser settings.
How long we keep your personal data
We keep personal data only for as long as necessary for the purposes we collected it for, including to satisfy any legal, accounting, tax, or reporting requirements.
- Enquiry and contact data: [e.g. up to 24 months after last contact, unless a business relationship begins]
- Client and contract data: [e.g. for the duration of the engagement plus the period required by law]
- Website analytics data: [e.g. as configured in our analytics tool]
When personal data is no longer needed, we securely delete or anonymise it.
How we protect your personal data
We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or alteration. These may include access controls, encryption in transit, secure hosting, confidentiality obligations for our team, and internal policies governing data handling.
No method of transmission or storage is completely secure, but we work to protect your data and to respond appropriately to any incident.
Your rights
Depending on where you live and which laws apply, you may have some or all of the following rights over your personal data.
Under UK GDPR and EU GDPR, you have the right to:
- Access — request a copy of the personal data we hold about you.
- Rectification — ask us to correct inaccurate or incomplete data.
- Erasure — ask us to delete your data in certain circumstances.
- Restriction — ask us to limit how we use your data.
- Portability — ask us to transfer your data to you or another provider in a structured, machine-readable format.
- Object — object to processing based on legitimate interests, or to direct marketing.
- Withdraw consent — where we rely on consent.
- Lodge a complaint — with your data protection authority (in the UK, the Information Commissioner’s Office, ico.org.uk; in the EU, your national supervisory authority).
Under California law (CCPA/CPRA), if you are a California resident you have the right to know what personal information we collect and how we use and share it, to request deletion, to correct inaccurate information, and to opt out of the “sale” or “sharing” of personal information. We do not sell your personal information. You have the right not to be discriminated against for exercising these rights.
Under Vietnam’s Personal Data Protection Decree (Decree 13/2023/ND-CP), you have rights including to be informed, to consent and withdraw consent, to access, to correct, to delete, and to object to certain processing of your personal data.
To exercise any of these rights, contact us at [privacy@dompartners.co]. We will respond within the timeframe required by the applicable law. We may need to verify your identity before acting on your request.
Children's privacy
Our Site and services are intended for businesses and professionals. They are not directed at children, and we do not knowingly collect personal data from anyone under the age of 16. If you believe a child has provided us with personal data, please contact us and we will delete it.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date above. If changes are significant, we will take reasonable steps to notify you. We encourage you to review this page periodically.
