Privacy Notice of Manpower Vietnam Co., Ltd.

DATED 14 October 2026

This Privacy Notice outlines how personal data is collected, used, disclosed, and otherwise processed by Manpower Vietnam Co., Ltd.

Personal data refers to digital data or information in other forms that identifies or can be used to identify a specific individual, including basic personal data and sensitive personal data. Personal data, once de-identified, is no longer considered personal data.

Information We Collect

Depending on our relationship with you, we may collect personal information about you in various ways, such as through our Sites and social media channels, at our events, through phone and fax, through job applications and in-person recruitment, and in connection with our interactions with clients, vendors and business partners.

We may collect the following types of personal information (as permitted under local law and with consent where necessary):

  • Information to identify you, such as your name and/or employee ID and, if you register on our Sites, your username and password;
  • contact information, such as postal address, email address and telephone number;
  • information about the organization you work for, your job title and/or department and the city/state/country or region you work in;
  • cookies, web beacons and web server logs by automated means, consistent with the Cookie Notice published on the Site you visit;
  • device information and browser locale preferences, e.g. your language and time zone;
  • dates, timestamps, and other records of our interactions with you and your usage of our Sites and services;
  • information you provide about family, friends, or other people you would like us to contact or may need us to contact; we will assume your contacts have previously authorized you to share their information for the purpose of such communication;
  • sensitive data, which may include racial or ethnic origin, political, religious, or philosophical beliefs, biometric data, data concerning health, information regarding sexual orientation; and
  • other information you may provide to us, such as in surveys or through the "Contact Us" feature on our Sites.

If you are a candidate accessing career or talent management support, or wishing to apply for a job, we may collect the following types of personal data (as permitted under local law and with consent where necessary):

  • CV/Resume data, which may include contact details, social media URL, employment history, education history, professional memberships, qualifications, knowledge, skills, abilities, languages, licenses held;
  • roles/opportunities of interest and salary expectations;
  • personality, preference, and skills data from assessment participation and/or coaching, including personality traits, skills, strengths, motivators, career aspirations, development opportunities;
  • a log of any events, interviews, training, or webinars attended or scheduled;
  • profile picture if you register on one of our Sites that offers that functionality;
  • ·video recording of any digital interview or interview practice you participate in;
  • gender and age range; and
  • information provided by job references or individuals requested to provide feedback on your work-related performance.

 If you are a job candidate, we may also collect the following information (as permitted by local law and with consent where necessary):

  • Social Security number, national identifier, or other government-issued identification;
  • citizenship and work authorization status;
  • bank account information;
  • tax-related information;
  • benefits information;
  • date of birth; and
  • results of drug tests, criminal and other background checks.

How We Use the Information We Collect

We may use the data collected for one or more of the following purposes depending on your consent to us and as permitted under applicable law:

For employees, associates, or job candidates

  • To assess your qualifications, experience, skills, competencies, and suitability for job positions, employment opportunities, or related services;
  • To carry out candidate selection, screening, referral, and recruitment support activities for our own recruitment processes or those of our clients, or to provide services to our clients;
  • Where applicable, to provide your information to our clients for their consideration, assessment, recruitment, execution of employment agreements, onboarding of personnel, and/or decisions regarding the use of our related services.

For candidates or participants that receive Right Management career and/or talent management services

  • To assess your suitability for job positions, employment opportunities, and/or career management and talent management programs provided to you at the request of our clients;
  • To carry out candidate selection, job placement, and the provision of career management and talent management services to you at the request of our clients;
  • To provide your information to other third parties for their consideration, assessment, and decision-making regarding your recruitment, engagement, admission to, or participation in career management and talent management programs at the request of our clients.

For individual experts we engage to support our career and talent management services

  • To assess your suitability for the relevant services, projects, or assignments;
  • To carry out the selection, placement, and management of our engagement and collaboration with you;
  • To provide your information to clients or business partners for their consideration, assessment, and decision-making regarding the use of your services or your participation in relevant projects.

For representatives of our potential business partners, clients (including the individual business partner, clients)

  • To contact you and introduce or advise you on our services, workforce solutions, and collaboration opportunities.
  • To understand your needs in order to recommend suitable services and solutions.
  • To send you marketing communications, newsletters, event invitations, surveys, and other information relating to our business activities.

For Representatives of vendors (including the individual vendor)

  • To contact and communicate with you regarding your products, services, or potential opportunities for collaboration with us;
  • To assess the suitability of you and the organization you represent in relation to our business needs;
  • To send you information, surveys, requests, and other communications relating to our vendor sourcing, evaluation, and selection activities.

General purpose

  • Creating and managing online accounts and optimizing and personalizing your user experience (please also consult the “Terms of Use” we publish on each Site footer);
  • Supporting our diversity and inclusion efforts and/or monitoring;
  • Ensuring reasonable adjustment for individuals with disabilities or medical conditions that require it;
  • Perform the contractual rights and obligations with applicable parties i.e. employees or associates, vendors, clients.
  • Enhancing the security of our network and information systems;
  • Performing data analytics, such as:

+ analysing platform usage across our users

+ analysing our job candidate base,

+ assessing individual performance and capabilities, including scoring on work-related skills,

+ identifying skill shortages,

+ using information to match individuals and potential opportunities,

+ analysing pipeline data (trends regarding hiring practices),

+ determining the effectiveness of our engagement strategy, and

+ determining the effectiveness of our products and services, and

+ develop and train artificial intelligence (AI), including machine learning, models.

  • Aggregating data as part of our analytics efforts;
  • To administer and process payments, invoices;
  • Internal Compliance and Protection of the Legitimate Interests of Manpower Vietnam Co., Ltd.: To carry out corporate governance, accounting, finance, auditing, internal control, risk management, and compliance with commercial contracts, employment agreements, business cooperation agreements, procurement contracts, service agreements, and other similar contractual arrangements, etc., and applicable laws; and to establish, exercise, or defend the legitimate rights and interests of Manpower Vietnam Co., Ltd.;
  • Compliance with Obligations to Government Authorities and Other Authorized Third Parties: To fulfill reporting, declaration, registration, record-keeping, and information disclosure obligations to competent government authorities; and to facilitate inspections, examinations, audits, investigations, tax finalization procedures, and other legal or regulatory proceedings as required by applicable law;
  • In a way consistent with the cookie notices we place on our Sites.

We also may use the information in other ways for which we provide specific notice at, or prior to, the time of collection. If we plan to use your personal information for a new purpose that differs significantly from the one originally disclosed or share it with a third party not outlined in this Privacy Policy, we will provide you the option to decide if you wish to proceed with this use or disclosure.

Artificial Intelligence (AI) / Machine Learning (ML)

Some of the services we provide may currently or in the future be enabled with AI, which may include AI/ML. With the assistance of AI, we can connect the right individuals with the best opportunities and get people into work more efficiently or prepare them for the job market more readily.

We perform risk assessments of the AI solutions we use at Manpower Vietnam Co., Ltd. and use human oversight to the fullest extent possible to ensure no automated decisions are made that produce any legal or similarly significant effects on individuals.

If you are receiving a service that includes the use of AI/ML, you shall be informed of this in more detail within the privacy notice provided in connection with that particular service.

How We Protect Personal Information

We maintain administrative, technical, and physical safeguards designed to protect the personal data we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Such measures are designed to provide an appropriate level of security taking account, on one hand, the technical state of the art and, on the other hand, the sensitivity of the personal data and the evaluation of potential risks.

To provide the appropriate security and confidentiality of personal data, we apply the following non-exhaustive list of measures, as appropriate:

  • Encryption of data at rest and in transit using industry standard encryption algorithms with appropriate key lengths;
  • Strong user authentication and role-based access controls;
  • Network monitoring solutions with events logging;
  • Hardened network infrastructure;
  • Measures for ensuring physical security of locations at which personal data are processed;
  • Business continuity and disaster recovery plans with periodic testing;
  • Incident management policy and processes;
  • Periodic vulnerability and penetration testing;
  • Periodic employee privacy and security training and awareness program;
  • Vendors and third party privacy and security assessments (where applicable);
  • Robust data processing and confidentiality agreements; and
  • Organizational measures for ensuring data minimization, purpose limitation, retention, data quality and accountability.

How Long We Store the Data We Collect

The personal information we collect is stored in an identifiable way only for the period of time we have determined is necessary, in light of the purposes for which the data was collected. We use the following criteria to determine our retention periods:

  • The necessity to retain the personal data collected, in order to offer services established in the context of the relationship among us, you, and a third party;
  • Your consent, where required;
  • The existence of specific legal obligations that make the processing and related storage necessary for specific period of times.

Information We May Disclose

We may disclose the personal data collected upon your consent and fullest extent to the compliance with applicable law, as described in this privacy notice, or in separate notices provided in connection with the services you are receiving or eligible for.

We may disclose a portion of personal data to vendors who perform services on our behalf, based on our instructions, to make our Sites and services available to you. Those vendors can include IT service and cloud providers, assessment providers, and applicant tracking systems providers. We strive to ensure this data is minimized to what is necessary to perform the specific services instructed. We do not authorize vendors, that process data on our behalf, to use or disclose the information except as necessary to perform services or comply with legal requirements. Personal data will not be sold, rented, distributed or made available to vendors for their own commercial purposes, including for their direct marketing purposes.

We also may disclose your personal data (i) with our subsidiaries and affiliates; (ii) if you are a job candidate, with clients who may have job opportunities available or interest in placing our job candidates; and (iii) with others with whom we work, such as consultants to provide the relevant career services or staffing suppliers who work with us to fill vacancies and place people into work (iv) if you are a recipient of talent management services, we may disclose the status or progress of your program to the sponsoring client, along with any applicable assessment outcomes.

In addition, we may disclose personal data about you (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials based on a lawful disclosure request; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

Links to External Tools and Resources

We may provide links to external third-party websites operated by organizations not affiliated with Manpower Vietnam Co., Ltd.. We do not disclose your personal information to organizations operating such linked third-party websites and we do not review or endorse, and are not responsible for, the privacy practices of these organizations. We encourage you to read the privacy policy of each website that you visit. This privacy notice applies solely to information collected by Manpower Vietnam Co., Ltd., its subsidiaries and affiliates (if any) through the services.

Data Transfers

We also may transfer the personal data we collect about you to countries outside of Vietnam. Those countries may not have the same data protection laws as Vietnam. When we transfer your information to other countries, we will protect that data as described in this Privacy Notice and any other specific notice given to you at the time of, or prior to, the processing.  Such transfers will comply with applicable law.

Subject to applicable law, you may obtain a copy of these safeguards by contacting us to to obtain information about the data protection measures implemented in connection with the processing of your personal data.

Your Privacy Rights and Choices

When authorized by applicable law, you may exercise the following specific rights:

- To be informed of the personal data processing

- To consent, refuse, or request withdrawal of consent to the personal data processing

- To view, modify, or request modification of their personal data;

- To request provision, deletion, and restriction of personal data processing; to object to personal data processing

- To complain, denounce, initiate lawsuits, or claim damages according to the law

- To request competent authorities or agencies, organizations, or individuals relevant to personal data processing to adopt solutions and measures to protect their personal data according to the law.

If you require more information about the processing of your personal data, please refer to the How to Contact Us section below.

How to Exercise your Privacy Rights and Choices

If you wish to exercise any of your data privacy rights or choices that you cannot perform yourself, you can do so via our Privacy Request Portal.

To protect your data, we may verify your email address and identity before processing your request. This may require a government-issued ID or proof of address. Verification information is used solely for this purpose and deleted once verification is complete. We will respond only to verifiable requests and may request additional information if needed. If we cannot verify your identity, we will explain why we are unable to process your request.

Privacy Rights Requests by Authorized Parties

You may designate an authorized representative to exercise your rights on your behalf. If an authorized representative submits a request on your behalf, they must also submit a document signed by you that authorizes your representative to submit the request on your behalf.

In addition, we may ask that both you, and your representative, follow the applicable process described above for identity verification.

Data Processing Relating to Minors

We respect the privacy of children. Our Sites and services are not typically designed for, or targeted to, children. If you are a parent or guardian, please contact us if you believe we may have collected information from your child, and we will review and take appropriate action.

Non-Discrimination Policy

Users of our Sites and services will not be subject to discriminatory treatment for exercising their privacy rights.

Please bear in mind that exercising some rights, like erasure, consent withdrawal or your right to object, may affect our ability to carry out and deliver some, or all, of the services you are eligible for.

Updates to Our Privacy Notice

From time to time, we may modify this Privacy Notice to reflect changes in technology, privacy practices and legal updates, or for other continuous improvement purposes. For significant changes, we will notify you by indicating at the top of each notice when it was most recently updated.

If we add additional services, or modify existing services, that we believe materially changes the nature of the processing you have been made aware of in this privacy notice and associated privacy notices provided to you in the delivery of our services, we will make reasonable efforts to provide you with additional notice. Depending on the reason for modification, we may also ask you to affirmatively consent to the changes. By continuing to use the services after such notice and/or consent, you agree to the terms of the revised Privacy Notice.

How to Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like to exercise your rights, please submit a request through our Privacy Request Portal or email: [email protected]