Updated and effective as of: January 01st, 2026

1. Introduction and Scope of Application

• Introduction: The Online Management Training Joint Stock Company and its member company, the KidsOnline One Member Limited Company (hereinafter referred to as “OMT” or “We”) is committed to protecting the privacy and personal data of all users and customers in accordance with Vietnamese legal regulations.
• Scope of Application: This Policy applies to all activities involving the collection, storage, use, sharing, protection, and processing of personal data of:
  • Customers and partners registering to use educational management systems provided by OMT, including: SchoolOnline (multi-level general school management system), KidsOnline (kindergarten educational institution management system), and CenterOnline (foreign language and extracurricular center management system).
  • Parents, students, teachers, and administrators using accounts on the aforementioned systems.
  • Visitors and users of services on OMT’s official website (https://omt.vn)  and other information pages/applications within the OMT ecosystem.

2. Definition of Personal Data

Under the Vietnam Personal Data Protection Law, personal data is classified into two groups that OMT may process:

• Basic Personal Data: Includes surname, middle name, and birth name; date, month, and year of birth; gender; contact address; phone number; email address; network connection information (IP, access history, browser information), personal images, and other basic identifying information declared by users or generated during system usage.
• Sensitive Personal Data: Includes information relating to children’s private life (students); health data or medical information recorded on the system (such as height, weight, and health status of kindergarten children on KidsOnline); personal location data determined via location services (if the user permits the application to access location services for attendance tracking/student pick-up).

3. Data Processing Principles

OMT is committed to strictly complying with the core principles of Vietnamese law:

1. Lawfulness: Only process personal data with the consent of the data subject (or the legal representative in the case of children) or in cases permitted by law without requiring consent.
2. Transparency: Data subjects are clearly informed of their personal data processing activities through this Policy.
3. Purpose Limitation: Data is processed only for the purposes that have been communicated and consented to.
4. Data Minimization: Only collect data that is strictly necessary to operate and provide educational services.
5. Accuracy: Data is updated and supplemented accurately based on the information provided by the data subject.
6. Security and Integrity: Apply appropriate technical and organizational measures to protect data against unauthorized or unlawful processing, accidental loss, or destruction.

4. Types of Data Collected by OMT

We collect the following specific types of information:

• Account Registration and Contact Information: Name of the school/educational institution, address, website/FaceBook, contact person’s name, title, email, and phone number.
• Educational Profile Information (for students/parents/teachers): Student’s full name, date of birth, class, profile picture, full name of parents or legal guardians, parents’ contact phone number, attendance information, academic evaluations, height, weight, and dietary plans (for kindergarten level).
• Technical and Service Usage Information: IP address, browser type, language used, access times, links clicked on the system, cookies, and mobile device identifiers.

5. Purposes and Grounds for Data Processing

• Purposes of Processing:
  • Setting up and managing user accounts on SchoolOnline, KidsOnline, and CenterOnline systems.
  • Providing interactive features and seamless communication between schools and families (sending notifications, updating academic progress, health, attendance, and nutrition charts).
  • Technical support, complaint resolution, system upgrades, and sending critical notifications (software updates, user manuals, service feedback).
  • Fulfilling reporting obligations or internal statistics to improve service quality.
• Grounds for Processing:
  • Voluntary and explicit consent of the data subject (or the parent or legal guardian of students under 16 years of age).
  • Execution of the educational management service contract signed between OMT and schools/educational institutions.
  • Compliance with legal obligations prescribed by the Ministry of Education and Training as well as current Vietnamese law.

6. Methods of Data Collection

OMT collects personal data through the following methods:

• Direct Collection: Users voluntarily declare information when registering an account, sending support requests, or when schools (OMT’s partners) directly input data into the system in accordance with their authority and service agreements with parents/students.
• Automatic Collection: Through monitoring technologies such as Cookies and system logs (log files) when users interact with OMT’s websites and software.

7. Data Sharing with Third Parties

OMT commits not to sell, trade, or disclose users’ personal information to third parties for unauthorized commercial purposes. We only share data in the following cases:

• Infrastructure Service Partners: Cloud hosting providers or integrated online tuition payment gateways on the application (after users agree to link their accounts) under strict binding personal data protection agreements.
• At the Request of Competent State Authorities: When there is a lawful written request from police authorities, courts, or education management agencies for investigation or inspection purposes.
• Protection of Lawful Rights: In emergency situations where it is necessary to protect the life or health of users, or to protect the lawful rights and interests of OMT before the law.

8. Data Retention and Erasure

• Retention Period: Personal data is stored for as long as the user’s account remains active on the system or until the service contract between OMT and the school is terminated, unless otherwise required by law regarding mandatory retention periods.
• Data Erasure: Upon receiving a valid request from the data subject or when services are terminated, OMT will completely delete or irreversibly encrypt (anonymize) personal data from its servers within the legally prescribed timeframe, ensuring that such data cannot be recovered.

9. Rights and Obligations of Data Subjects

In full compliance with the Vietnam Personal Data Protection Law 2025, users (data subjects) hold the following rights:

• Right to be Informed and to Consent: To be clearly notified of data processing activities before giving consent.
• Right to Access and Rectify: To access, check, and correct their personal data directly on the application or website.
• Right to Withdraw Consent: To withdraw consent to process data (Note: Withdrawing consent may affect the ability to use certain features of the system).
• Right to Erasure: To request OMT to delete their personal data when it is no longer needed or when a violation is detected.
• Right to Restrict or Object to Processing: To request a restriction on the scope of data processing or to object to data processing for direct marketing purposes.
• Obligations: Users are obligated to provide accurate and lawful personal information and to maintain the security of their own accounts and access passwords, and not share them with others.

10. Children’s Data Protection

As a developer of kindergarten and school platforms (especially KidsOnline and SchoolOnline), OMT prioritizes children’s data protection above all:

• We only collect and process the personal data of children (persons under 18 years of age) after obtaining the consent of their parents or legal guardians in accordance with the Law on Children and the Personal Data Protection Law.
• Prior to processing the data of children aged 7 years and older, the system will seek the consent of the child themselves in accordance with legal processes (if system features require direct interaction from the child).
• We will immediately stop processing, delete, or destroy children’s data if parents or legal guardians withdraw their consent or at the request of competent authorities.

11. Data Security Measures

OMT implements advanced technical and organizational measures to ensure information security:

• Data Encryption: Applying HTTPS/SSL secure transfer protocols for all data transmitted between user devices and servers; one-way encryption for user passwords.
• Access Control: Restricting access to personal data within OMT; only designated personnel with specific duties are granted access to data for technical support or service operation.
• Secure Infrastructure: Servers are hosted in international-standard data centers in Vietnam, equipped with intrusion prevention firewalls, automated malware scanners, and periodic data backup systems.

12. Data Breach Incident Response Procedure

In the event of a cybersecurity incident or unauthorized intrusion leading to a risk of leakage, loss, or destruction of personal data:

1. Immediate Remediation: OMT’s technical team will immediately isolate the affected area, prevent the incident from spreading, and patch the security vulnerability.
2. Authority Notification: OMT commits to compiling an incident file and notifying the Department of Cybersecurity and High-Tech Crime Prevention (Ministry of Public Security) within a maximum of 72 hours from the detection of the incident, in accordance with Decree 13/2023/NĐ-CP.
3. User Notification: Send direct notifications via email or the application to affected data subjects to guide them on preventive risk measures (e.g., changing passwords).

13. Contact for Exercising Data Subject Rights

If users have any questions, feedback, or wish to exercise their rights as a data subject (such as requesting data deletion, correction, or withdrawing consent), please contact our Personal Data Protection Department through the following channels:

• Organization in charge: The Online Management Training Joint Stock Company (or KidsOnline One Member Limited Company)
• Office Address: 791 Building, No. 27-31/59 Lang Ha, O Cho Dua Ward, Hanoi
• Phone: 1900 0362 (in Vietnam)
• Inquiry Email Addresses:
  • For SchoolOnline: SchoolOnline@omt.vn 
  • For KidsOnline: KidsOnline@omt.vn 
  • For CenterOnline: CenterOnline@omt.vn 

14. Policy Updates

This Privacy Policy may be adjusted and updated at any time to ensure ongoing compliance with changes in Vietnamese law, OMT’s actual operating conditions, and feedback from customers.

When major changes or significant updates are made, we will publicly post the new version on our official website (https://omt.vn) and/or send notifications directly to users via the applications. Continual use of the services after the updated policy takes effect constitutes consent to the modified terms.