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Personal informationDATA PROCESSING

Personal information in work we carry out for customers.

This applies if you engage us, or use our platform.

0. When this applies

This document applies if you engage us for development or related work, or use our watch-over and safety-confirmation platform. It does not apply to simply visiting our website; that is covered by our Privacy Policy.

Where this document and an individual contract between you and TKS differ, the contract prevails.

1. Our capacity

When we carry out work for a customer, or deploy and operate our platform for their business, the customer is the controller and TKS processes the personal data on their behalf.

What is collected, what it is used for, how long it is kept, and how consent is obtained from the individuals concerned are decided by the customer. We process only within the scope of our contract with them and their instructions. We do not set purposes of our own.

2. Contract development and AI agents

2.1 Stored data

Development and verification use data from verification environments. As a rule we do not take production data. Where production data does need to be handled, its scope is fixed in writing before work begins.

2.2 Where we work

By default our working area is staging and verification environments, and releases go through GitHub. Where work in the production environment is needed, the scope of privileges, the recording of operations, and the approval procedure are agreed in the contract beforehand.

2.3 Processing by AI

Which code and which data are passed to AI is fixed in writing before work begins. Automated processing by AI runs in an isolated environment and, unless expressly agreed in the contract, does not connect directly to your production systems. The model used, the processing region, and whether the data may be used secondarily for training are likewise fixed in writing before work begins and recorded in the contract.

These points are set out in more detail under Quality & Security.

3. The watch-over and safety-confirmation platform

3.1 Categories of information that may be handled

The following are categories the platform’s features may involve. What is actually handled depends on which features the customer has enabled. Not every deployment involves all of them.

(1) Basic information about users. Name, organisation, email address, telephone number and similar details the customer registers to identify users.

(2) Location data. Position derived from GPS, Wi-Fi and wireless network positioning, where the watch-over and safety-confirmation features are enabled. Collection follows the application’s settings, and a user can stop it through their device settings.

(3) Safety status. Responses to safety confirmations, whether a response was received, and when a confirmation was carried out.

(4) Emergency contact information. Contacts registered as emergency contacts, and the fact and time of an emergency alert. Where a feature that reads contact details is enabled, its scope is set by the customer.

(5) Vehicle and asset movement data. Where fleet or asset tracking is enabled: position, movement, and information from the device’s sensors.

(6) Data received from devices and tags. Identifiers, status and position received from Bluetooth tags, GPS units and similar devices.

(7) Technical information about devices and connections. IP address, device type, application version, notification delivery status and operational logs, to the extent needed to keep the service running and investigate faults.

3.2 Information about children

Our platform may be deployed to watch over children or older people. Even then, obtaining consent from the individuals concerned and from a parent or guardian is the responsibility of the customer, as the controller.

3.3 Special-care-required personal information

Where health status or other information that may qualify as special-care-required personal information under the APPI needs to be handled, we agree its scope, how it is obtained, and how consent is obtained with the customer in writing beforehand. We do not begin collecting such information on our own initiative.

4. Purpose limitation

Information under sections 2 and 3 is used solely to provide the service to that customer and keep it running.

We do not use it for our own sales or marketing, serve advertising from it or pass it to advertising businesses, sell it to third parties, use it for statistical purposes outside what the contract provides for, or make it available to another customer or carry it over to another customer’s project.

5. Disclosure and sub-processing

We do not disclose the information to third parties except on the customer’s instructions or where required by law.

We state in the contract who actually touches the source code and the personal data. Where a partner is involved, their scope and privileges are fixed in writing in the contract. We do not sub-contract without your agreement.

Where delivering the service involves cloud providers, notification delivery providers or telecommunications carriers, we present the providers, the countries they operate in, and the information they handle at deployment, and use them with your agreement.

6. Cross-border transfer, security, and contact

For these, sections 5, 6 and 9 of our Privacy Policy apply.

Requests from individuals should go first to the customer providing the service to them, as the controller. Where a request reaches us through that customer, we act on their instructions. If you contact us directly, we will pass the request to the customer.

Effective from 20 September 2026 / Last revised 20 September 2026

TECH KNOWLEDGE SOLUTION VIETNAM CO., LTD.

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