This Policy describes how TMI Joint Stock Company ("X-Talent") collects, uses, shares, and protects Users' personal data when accessing or using the X-Talent Service.
This Policy constitutes an integral part of the X-Talent Terms of Service; capitalized terms in this Policy, unless otherwise defined, have the meanings ascribed to them in the Terms of Service.
Registering an account, accessing, or using any feature of the Service signifies that the User has read, understood, and agreed to this Privacy Policy.
01Scope of Collection
When using the Service, X-Talent may collect:
- Identification information: full name, date of birth, gender, phone number, email address, residential information, avatar profile photo
- Professional information: education, work experience, skills, certifications, career orientation, desired income level
- Practice content: interview responses, audio and video recordings (if the User grants microphone/camera permissions)
- Technical and behavioral data: IP address, device type, browser, search history, and application activity on the Platform
Access to microphone, camera, and other device permissions is only executed after explicit User authorization and can be revoked at any time in device settings.
02Purposes and Legal Basis for Processing
Data is processed to: provide the Service pursuant to contracts with Users; connect Candidates with Employers based on Candidate consent; enhance Service quality; ensure system security and fraud prevention; and fulfill statutory obligations.
03Data Sharing
Data may be shared with:
- Employers: according to Candidate profile visibility settings or when Candidates actively submit job applications
- Infrastructure, AI service, cloud storage, and payment providers: strictly within the scope necessary for operations, bound by contractual confidentiality terms
- Competent state authorities: upon lawful written request in accordance with applicable laws
Data may be stored or processed on servers located within and/or outside the territory of Vietnam. In the case of cross-border data transfers, X-Talent fulfills all regulatory procedures required by Vietnamese personal data protection laws.
X-Talent does not sell Users' personal data to third parties.
04User Rights
Users have the right to: know, provide or withdraw consent, access, rectify, request provision of, delete, restrict processing of, object to processing of, and file complaints regarding their personal data pursuant to applicable laws.
Requests should be submitted to: contact@x-talent.vn. X-Talent responds within the statutory timeline.
05Account Deletion and Retention
- When a User deletes their account or an account is terminated, personal data will be marked for deletion and removed from public display areas.
- A portion of data may persist in technical backups for up to 30 days before permanent purge, or longer where required by law (e.g., transaction records, dispute resolution records).
- X-Talent reserves the right to delete accounts that remain inactive for 12 consecutive months, following at least 30 days prior notification sent to the registered email address.
06Data Controller and Contact Information
- Operating Entity: TMI Joint Stock Company
- Address: 21st Floor, VIWASEEN Tower, 48 To Huu, Dai Mo Ward, Hanoi City, Vietnam.
- Enterprise Code: 0109904638
- Contact Email: contact@x-talent.vn
- Website: https://x-talent.vn
- Effective Date: 01/01/2026