Effective Date: March 24, 2025 (Last Updated: May 15, 2025)
Company: Olinno Technology Ltd. ("Enfue," "we," "us," or "our")
Licensed: 0401950376
Incorporated date: January 11, 2019
Code: enfue.com (a product of Olinno Technology Ltd.)
Address: 45 Nguyen Huu An, Son Tra district, Danang, Vietnam
1. Our Commitment to Your Privacy
Welcome to Enfue.com. We are committed to protecting the privacy and security of your personal data. This
Privacy Policy ("Policy") explains how we collect, use, process, share, and protect your personal data when you
access or use our HR recruitment platform and associated services (collectively, the "Services").
This Policy is designed to comply with applicable data protection laws, including Vietnam’s Decree No.
13/2023/ND-CP on Personal Data Protection ("Decree 13"). By using our Services, you acknowledge that you have
read, understood, and agree to the terms of this Privacy Policy and our Terms of Service.
2. Definitions
Personal Data: means any information in the form of symbols, letters, numbers, images, sounds, or similar forms in an electronic environment that is associated with a particular individual or helps to identify a particular individual. This includes basic personal data and sensitive personal data as defined under Decree 13.
Processing of Personal Data: means an activity or activities that impact personal data, such as collection, recording, analysis, confirmation, storage, rectification, disclosure, combination, access, retrieval, revocation, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion or destruction of personal data, or other related actions.
Data Controller: means an organization or individual that decides the purposes and means of processing personal data. Enfue acts as a Data Controller for the data it collects directly from users for its own purposes.
Data Processor: means an organization or individual that processes personal data on behalf of a Data Controller through a contract or agreement with the Data Controller.
User, You or Your: refers to any individual accessing or using our Services, including Companies, Recruiters, and Candidates as defined in our Terms of Service.
3. Information We Collect
We collect Personal Data to provide and improve our Services. The types of Personal Data we collect depend on your interaction with us:
3.1. Information You Provide Directly (Mandatory and Voluntary):
Account Registration Data (Mandatory for certain services):When you create an account, we collect basic personal data such as your full name, email address, phone number, company name (if applicable), job title, and password. Failure to provide mandatory data may limit your ability to use certain Services.
Profile Information (Voluntary, but may be necessary for full functionality):For Candidates, this may include your resume/CV, employment history, education, skills, qualifications, salary expectations, and references. For Companies/Recruiters, this may include company details, job postings, and hiring preferences.
Payment Information (Mandatory for paid services):Billing address, payment card details (processed securely by our third-party payment processors), and transaction history.
Communications Data (Voluntary):Information you provide when you contact us for support, provide feedback, or participate in surveys or promotions.
3.2. Information Collected Automatically:
Usage Data: Information about how you use our Services, such as features accessed, pages viewed, search queries, application submissions, and activity logs.
Device and Technical Data: IP address, browser type and version, operating system, device identifiers, time zone setting, and referring URLs.
Cookies and Similar Tracking Technologies: We use cookies, web beacons, pixels, and other
tracking technologies to collect information about your browsing activities, preferences, and to enhance your
user experience. Please see Section 9 ("Cookies and Tracking Technologies") for more details.
3.3. Information from Third Parties:
We may receive Personal Data about you from third-party services if you choose to integrate them with your Enfue account (e.g., social media login like Google, Facebook, LinkedIn, or applicant tracking systems). This data is collected in accordance with the authorization procedures determined by such third-party services.
Publicly available sources, where permitted by law.
4. How We Use Your Information (Purposes of Processing)
We process your Personal Data for the following purposes, based on lawful grounds as required by Decree 13:
To Provide and Manage Our Services (Core Purpose - based on contract performance and legitimate interest):
Creating and managing your user account.
Enabling you to post and apply for jobs, manage candidate profiles, and utilize HR tools.
Processing transactions and managing subscriptions.
Facilitating communication between Companies/Recruiters and Candidates.
To Improve and Personalize Our Services (Legitimate Interest, Consent where required):
Analyzing usage patterns to understand user needs and enhance platform functionality.
Personalizing your experience, such as suggesting relevant jobs or candidates.
Conducting research and development.
For Communication and Support (Legitimate Interest, Contract Performance):
Responding to your inquiries, requests, and providing customer support.
Sending you service-related announcements, updates, security alerts, and administrative messages.
For Marketing and Promotions (Consent, Legitimate Interest where permissible):
Sending you information about new products, features, special offers, and events that may be of interest to you. You can opt-out of marketing communications at any time (see Section 8).
For Security and Legal Compliance (Legal Obligation, Legitimate Interest):
Monitoring and preventing fraudulent or illegal activities.
Enforcing our Terms of Service and other policies.
Complying with applicable laws, regulations, legal processes, or governmental requests, including those under Vietnamese law.
We will obtain your explicit consent before processing your Personal Data for any purpose not covered in this Policy or if required by applicable law (especially for sensitive personal data or new processing purposes).
5. Sharing and Disclosure of Information
We do not sell your Personal Data. We may share your Personal Data with the following categories of third parties only in the ways that are described in this Privacy Policy and in accordance with Decree 13:
Employers and Recruiters: If you are a Candidate and apply for a job or make your profile searchable, your Personal Data (e.g., CV, contact information) will be shared with the respective Companies/Recruiters.
Candidates: If you are a Company/Recruiter, information you post (e.g., job descriptions, company profile) will be visible to Candidates and other users.
Service Providers (Data Processors): We engage third-party service providers to perform functions on our behalf, such as payment processing, data analytics, cloud hosting, email delivery, and customer support. These providers are contractually obligated to protect your Personal Data and can only use it for the specific services they provide to us.
Third-Party Integrations: If you choose to connect third-party services to your Enfue account, we may share your information with these services as directed by you.
Legal Requirements: We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation (e.g., a subpoena or court order), protect and defend our rights or property, prevent or investigate possible wrongdoing in connection with the Services, protect the personal safety of users or the public, or protect against legal liability.
Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your Personal Data may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Platform of any change in ownership or uses of your Personal Data.
With Your Consent: We may share your Personal Data with other third parties with your explicit consent.
6. Data Security
We implement appropriate technical and organizational security measures designed to protect your Personal Data from unauthorized access, use, alteration, disclosure, loss, or destruction, in accordance with industry standards and Decree 13. These measures include encryption, access controls, secure servers, and regular security assessments.
However, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
7. Data Retention
We will retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, and in accordance with Decree 13.
The criteria used to determine our retention periods include:
The length of time you have an active account with us.
The nature and sensitivity of the Personal Data.
The potential risk of harm from unauthorized use or disclosure.
The purposes for which we process your Personal Data and whether we can achieve those purposes through other means.
Applicable legal, regulatory, tax, accounting, or other requirements.
Upon expiration of the retention period, your Personal Data will be deleted or anonymized, unless otherwise required by law.
8. Your Rights Regarding Your Personal Data
Under Vietnam’s Decree 13 and other applicable data protection laws, you have certain rights regarding your Personal Data. Subject to legal limitations, these rights may include:
Right to be Informed: To know about the processing of your personal data.
Right to Consent (and Withdraw Consent): To consent to the processing of your personal data and to withdraw your consent at any time (withdrawal will not affect the lawfulness of processing based on consent before its withdrawal).
Right to Access: To request access to the Personal Data we hold about you and receive a copy of it.
Right to Rectification: To request correction of inaccurate or incomplete Personal Data.
Right to Erasure (Deletion): To request the deletion of your Personal Data under certain conditions.
Right to Restrict Processing: To request the restriction of processing of your Personal Data under certain conditions.
Right to Data Portability: To request the transfer of your Personal Data to another organization, or directly to you, in a structured, commonly used, and machine-readable format, under certain conditions.
Right to Object: To object to the processing of your Personal Data under certain conditions (e.g., for direct marketing purposes).
Right to Complain: To lodge a complaint with the relevant data protection authority if you believe your rights have been violated.
Right to Claim Compensation: To claim compensation for damages caused by violations of personal data protection regulations.
How to Exercise Your Rights: You can exercise these rights by contacting us using the details
in Section 13 ("Contact Us"). We may need to verify your identity before processing your request. We will
respond to your request within the timeframes stipulated by Decree 13.
You can also manage some of your information directly through your account settings on the Platform (e.g.,
updating your profile, opting out of marketing emails by using the "unsubscribe" link).
9. Cookies and Tracking Technologies
We use cookies and similar tracking technologies (e.g., web beacons, pixels) to operate and improve our Services, enhance your user experience, and analyze trends.
What are Cookies? Cookies are small text files stored on your device when you visit a website. They help us remember your preferences, understand how you interact with our Platform, and personalize content and advertisements.
Types of Cookies We Use:
Essential Cookies: Necessary for the Platform to function properly (e.g., for authentication, security).
Performance and Analytics Cookies: Help us understand how users interact with our Services, identify areas for improvement, and measure the effectiveness of our content (e.g., Google Analytics).
Functionality Cookies: Remember your choices and preferences to provide a more personalized experience.
Marketing Cookies: Used to deliver relevant advertisements to you and track the effectiveness of our marketing campaigns.
Your Choices: Most web browsers allow you to control cookies through their settings. You can usually set your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you disable cookies, some features of our Services may not function properly. We may also provide a cookie consent management tool on our Platform for more granular control where required by law.
10. International Data Transfers
Your Personal Data may be processed and stored in Vietnam or other countries where our service providers are located. If we transfer your Personal Data outside of Vietnam, we will take appropriate measures to ensure that your data receives an adequate level of protection in accordance with Decree 13 and other applicable data protection laws. This may include implementing Standard Contractual Clauses or relying on other legally recognized transfer mechanisms and, where required, conducting data transfer impact assessments and obtaining necessary approvals.
11. Children’s Privacy
Our Services are not directed to individuals under the age of 16 (or the minimum age stipulated by applicable local law for data processing consent). We do not knowingly collect Personal Data from children. If we become aware that we have inadvertently collected Personal Data from a child without verifiable parental consent, we will take steps to delete such information from our records promptly. If you believe we might have any information from or about a child, please contact us.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or
service offerings. We will notify you of any material changes by posting the new Policy on our Platform and
updating the "Effective Date" at the top. We encourage you to review this Policy periodically for the latest
information on our privacy practices. Your continued use of the Services after any changes to this Policy
constitutes your acceptance of the revised Policy.
13. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, or if you wish to exercise your rights, please contact us at:
Olinno Technology Ltd. Attn: Legal Department Address: 45 Nguyen Huu An, Son Tra district, Danang, Vietnam Email for Privacy Inquiries: privacy@enfue.com General Support: support@enfue.com
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.
Note on Vietnamese Version: While this Policy is provided in English, if a Vietnamese version is made available, the Vietnamese version shall prevail in case of any discrepancies, given that our operations are primarily governed by Vietnamese law.