Part A

Privacy Information

This privacy information informs you in Part A about the processing of your personal data in connection with using our website www.vietnam.ahk.de (hereinafter collectively referred to as the “Website”) and the features made available through it; in Part B, we inform you about local data protection legal requirements and special forms of processing.

I. Name and Address of the Controllers

The Website is operated by DIHK and DIHK DEinternational GmbH, both at Breite Straße 29, 10178 Berlin, in joint responsibility in relation to topics, together with

AHK Vietnam
Office in Ho Chi Minh City:
Le Duan 33, Sai Gon District
70000 Ho Chi Minh City, Vietnam
Tel.: +84 3823 8775

Office in Hanoi:
54 Lieu Giai, Giang Vo District
11100 Hanoi, Vietnam
Tel.: +84 (24) 3825 1420
E‑Mail: info@vietnam.ahk.de

Excerpts from the agreement on joint responsibility are available upon request. Please contact ahk@ahk.de.
 

Processing operations for which AHK is solely responsible are described below in Part B.

II. EU Representative

Since AHK is not established in the EU, it has appointed DIHK, Breite Straße 29, 10178 Berlin, as its EU Representative under Article 27 of the General Data Protection Regulation (“GDPR”).

III. Name and Address of the Data Protection Officer

The data protection officer of the controller is:

Contact point for Data Protection Matters at AHK Vietnam
Office in Hanoi:
54 Lieu Giai, Giang Vo District
11100 Hanoi, Vietnam
Tel.: +84 (24) 3825 1420
E‑Mail: pdp@vietnam.ahk.de

IV. Provision of the Website and Creation of Server Log Files

1. Data Categories and Description of the Data Processing

Each time our website is accessed, the following data are processed:

• IP address;
• Date and time of access;
• Time zone difference to Greenwich Mean Time (GMT);
• Specific website accessed;
• Access status / HTTP status code;
• Amount of data transferred each time;
• Web page from which you came;
• Browser;
• Operating system and its interface;
• Language and version of the browser software;
• Internet service provider (collectively referred to as “server log files”).

2. Legal Basis and Purpose of Data Processing

The legal basis for processing your data in connection with your use of our Website is Article 6(1) sentence 1 lit. e), and paragraph 3 GDPR in conjunction with § 10a of the IHKG (German law), concerning the public tasks assigned to us, especially representing the overall interests of related commercial operators (“Gewerbetreibenden”) in the Federal Republic of Germany at national, European and international levels; promoting commercial economy; coordinating and promoting the AHK network including delegate offices and representations; and foreign trade promotion of the Federal Republic of Germany. In order to promote this purpose, a functional Website is made available, and the related processing of personal data takes place.

3. Duration of Storage

Server log files are deleted at the latest after seven days. In case of errors, logs are also generated, which are stored for a period of 30 days for error analysis and troubleshooting, and then deleted.

4. Recipients

Access to server log files is granted to those employees of the Controllers who are responsible for maintaining the Website. In this context, it may happen that employees of DIHK DEinternational GmbH have access to your personal data. For this reason, AHK, DIHK, and DIHK DEinternational GmbH have concluded a data protection group agreement that regulates the processing and transfer of personal data within the AHK network.

We also use third-party services on our Website. More information about these services and the related data processing can be found under [Part B] and in the cookie settings.

V. Website Analytics with PIWIK PRO Analytics Suite

1. Data Categories and Description of the Data Processing

We use Piwik PRO Analytics Suite as our website analytics software. We collect data about website visitors in the form of server log files and based on cookies. An overview of the cookies used in this context is available at: https://help.piwik.pro/support/privacy/cookies-created-for-piwik-pro-users/. A description of server log files can be found under IV.1 in Part A.

2. Legal Basis and Purpose of Data Processing

The purpose of using PIWIK PRO Analytics Suite is to trace certain usage patterns, such as bounce rate, page views, and session duration, to understand how our website is used. We may also create user profiles based on browser history to analyze visitor behavior, display personalized content, and conduct online campaigns. The legal basis for analytics and conversion tracking is your consent under Article 6(1) sentence 1 lit. a) GDPR.

3. Duration of Storage

If you give us your consent for analytics and conversion tracking, we store your personal data for a period of 25 months and then delete it, unless you have revoked the consent; in that case, from receipt of the revocation, we no longer store personal data. Your revocation only takes effect for the future and does not affect the processing of data until the moment of revocation.

4. Recipients

Recipients of your personal data are employees of DIHK DEinternational GmbH and AHK, responsible for maintaining the website. Furthermore, it may happen (for example, in troubleshooting cases) that employees of PIWIK PRO Analytics Suite, AHK, and DIHK DEinternational GmbH have access to your personal data. PIWIK PRO Analytics Suite uses, in the context of its service provision, third parties, some of whom are located in the USA, so it may occur that your personal data is transmitted to these third parties. Further information can be found in the privacy policy of PIWIK PRO.

VI. Use of Cookies

1. Data Categories and Description of the Data Processing

We use Piwik PRO to manage consents and collect, to that end, personal data via cookies. We also deploy cookies to make our website more user‑friendly. Cookies are small text files stored on your computer. An overview of the cookies used in this context may be obtained at: https://help.piwik.pro/support/privacy/cookies-created-for-visitors-by-piwik-pro/. Some of the cookies we use are deleted from your hard drive at the end of your browser session (“session cookies”). Furthermore, we also use persistent cookies, which remain on your device, e.g., to recognize you on your next visit.

If cookies are set, they process certain user information individually, as described in the link.

You can control the use of cookies at any time via your browser settings. You have the option there to delete or block cookies. However, this may lead to some functionality of our website being restricted. On our website,e we also use social media buttons; further information on this is under section VIII.

2. Legal Basis and Purpose of Data Processing

The legal basis for managing consents via PIWIK PRO is our legitimate interest under Article 6(1) sentence 1 lit. f) GDPR in a lawful and usage‑specific consent management.
If individual cookies set by us also process personal data, then, depending on the specific cookie, the processing is based on the following legal grounds:

• Necessary cookies: Processing of personal data by necessary cookies is based on our legitimate interest pursuant to Article 6(1) sentence 1 lit. f) GDPR, since these cookies are required for the proper functioning of the website. Furthermore, setting the cookie is based on § 25 para. 2 no. 2 TDDG, which states that storing information on your device or accessing information already stored on your device is strictly necessary so that we can provide a digital service explicitly requested by you — our Website.
• All other cookies: The setting of these cookies under § 25 para. 1 TDSG and the processing of personal data is carried out on the basis of your consent under Article 6(1) sentence 1 lit. a) GDPR. These cookies collect information about your use of our website, which we use to improve functionality and your user experience.

3. Duration of Storage

Data for managing consents is stored for a period of 25 months.
An overview of the cookies set by us and their storage duration can be found at: https://help.piwik.pro/support/privacy/cookies-created-for-visitors-by-piwik-pro/.

4. Recipients

Access to your personal data is granted to those employees of the Controllers who are responsible for maintaining the Website. Furthermore, it may happen (for example, in troubleshooting cases) that employees of PIWIK PRO have access to your personal data. Where PIWIK PRO employees receive access to personal data, we have entered into the requisite agreements to protect your personal data, in particular concluding data processing contracts pursuant to Article 28 GDPR, under which PIWIK PRO is committed to confidentiality.

VII. Map Service

1. Data Categories and Description of the Data Processing

We have integrated the map service “OpenStreetMap” (“OSM”) into our Website. This is an offering of the OpenStreetMap Foundation, based at St John’s Innovation Centre, Cowley Road, Cambridge, CB4 0WS, United Kingdom, which is responsible for OSM in the sense of Article 4 No. 7 GDPR.

The map display is only shown after you have given your consent.
To display OSM, server log files are transmitted to the OpenStreetMap Foundation. Information on how the OpenStreetMap Foundation processes your personal data can be found in the data protection notices of the OpenStreetMap Foundation at https://osmfoundation.org/wiki/Privacy_Policy.

2. Legal Basis and Purpose of Data Processing

The legal basis for processing your personal data is your consent under Article 6(1) sentence 1 lit. a) GDPR. The processing of your personal data serves the purpose of displaying a map for the purpose of showing location and planning routes.

3. Duration of Storage

Information on processing and retention period can be found at: https://osmfoundation.org/wiki/Privacy_Policy

4. Recipients

The OpenStreetMap Foundation is a recipient of your personal data.

VIII. Automated Decision‑making and Profiling

Except for the processing described under section V, your personal data are not used by us for automated decision‑making and/or profiling.

IX. Obligation to Provide Personal Data

You may choose not to provide us with your personal data or provide it only incompletely. In such a case, for example, if you prevent the storage of a cookie, this may lead to some functionalities of our Website not being usable. If you wish to become a member and do not provide us with your personal data, then it may be that we cannot process your membership application.

X. Rights of the Data Subject

You may contact AHK directly, either in writing or by e‑mail at pdp@vietnam.ahk.de, to exercise the following rights:

• Right of access to your data, to inspect and verify them;
• Receipt of a copy of your personal data;
• Rectification, erasure or restriction of processing, including the right to complete or correct incomplete or false data by supplementary declaration;
• Right to object to the processing; please note that according to Article 21 GDPR, you have a right to object to the processing of personal data processed by us on the basis of legitimate interests under Article 6(1) sentence 1 lit. f) GDPR; a right of objection exists insofar as the data processing is based on reasons arising from your particular situation; insofar as the objection refers to processing of personal data for the purposes of direct marketing, you have a general right of objection without needing to specify a particular situation;
• You can receive the provided data in a structured, commonly used, and machine‑readable format and transmit that data to another controller, provided that you have given consent to the processing or that the processing is based on a contract.

If you have given us consent to the processing of your personal data, you may revoke this consent at any time with effect for the future.

You also have the right to lodge a complaint with a supervisory authority in connection with the processing of your personal data. To exercise this right, you may contact the authority responsible for your place of residence or the authority competent for AHK:
The supervisory authority responsible for our EU representative is the Federal Commissioner for Data Protection and Freedom of Information (Bundesbeauftragte für den Datenschutz und die Informationsfreiheit), Graurheindorfer Str. 153, 53117 Bonn.

Part B

Local Data Protection Legal Requirements and Special Forms of Processing

I. Special Forms of Processing:

1. Newsletter

i. Data Categories and Description of Data Processing

On our Website, there is the option to subscribe to a free newsletter, with which we inform you e.g., about our offerings, our events, and current economic topics. If you subscribe to our newsletter, we process the following personal data:

• Title,
• First name,
• Last name,
• Email address, together with the date and time of subscription.

For subscribing to our newsletter, we use the so‑called double opt‑in procedure. That means that after your registration, we send you an email to the address provided, asking you to confirm your newsletter subscription. The purpose of this procedure is to prove your registration and, if necessary, avoid misuse of your personal data.

If you subscribe to our newsletter and have given us the appropriate consent, then we also evaluate your user behavior, in particular to analyze how our newsletters are opened and used. We specifically track,

• if and when you open our newsletter,
• which links are clicked, and
• analyze how you interact with the content of our newsletter (collectively referred to as “newsletter‑tracking”).

This is achieved with the help of a small, invisible image file or a code embedded in our website/email. When you visit our Website / open the newsletter, this image file is downloaded from the server, and your interaction with our newsletter is recorded. For the evaluation, we link server log files with the web beacon, your email address, and add an individual ID.

ii. Legal Basis and Purpose of Data Processing

The legal basis for subscribing to our newsletter and its distribution is your consent under Article 6(1) sentence 1 lit. a) GDPR. You can revoke your consent to receive the newsletter at any time. You may do so by clicking the link provided at the end of each newsletter, or by email to marcom@vietnam.ahk.de.

The collection of your email address serves to inform you about AHK‑news as desired.

iii. Duration of Storage

Your personal data will be processed by us until you revoke your consent. As part of periodic reviews (approx. every 2 years), we will ask again whether you are still interested in receiving our newsletter. If you do not confirm such interest, we will cease sending the newsletter. You always have the opportunity to subscribe again.

iv. Recipients

To send our newsletter, we use external service providers, some of which are located outside the EU. In those situations, we conclude data processing agreements which include the EU standard contractual clauses if there is no adequacy decision. You may view the EU standard contractual clauses at https://eur‑lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de.

To optimize our newsletter offering, we use personalized newsletter tracking. In doing so, we record, in addition to the email address, also the activities related to the newsletter dispatch (click behavior).

v. Right to Object and Deletion Option

Subscription to the newsletter can be terminated by the data subject at any time by objection. For that purpose there is a corresponding link in each newsletter. Alternatively, you can also write to us by email: marcom@vietnam.ahk.de

2. Contact Form and Email Contact

i. Data Categories and Description of Data Processing

If you use the contact form embedded on our Website to contact us, we process your full name,

• your company,
• your email address, and
• a message. The stated data are marked as mandatory.
• You may also voluntarily provide the following information: your phone number.

We also process server log files (see IV.1) in addition to your personal data described here at the moment you access our contact form.

Alternatively to our contact form, contacting us via the provided email address is possible. In this case, the personal data of the user transmitted via the email is processed.

ii. Legal Basis and Purpose of Data Processing

The legal basis for processing your data marked as mandatory is, under Article 6(1), sentence 1, lit. b) GDPR, your request to us. The same applies to a contact initiated by email.

The legal basis of data that are not marked mandatory and that you voluntarily provide is your consent under Article 6(1) sentence 1 lit. a) GDPR. You can revoke consent at any time by email to marcom@vietnam.ahk.de. We store your data until we receive a corresponding revocation.

We process your personal data in order to handle and respond to your inquiry.

iii. Duration of Storage

Your personal data will be deleted once your inquiry has been fully answered. If you have given us consent, then we will process your data until you revoke that consent or until your inquiry has been fully answered.

iv. Recipients 

Those employees of AHK and DIHK DEinternational GmbH who are tasked with answering inquiries will have access to your personal data. Additionally, it may happen that employees of DIHK DEinternational GmbH and/or other AHK offices also receive access to your personal data. For this purpose, we have concluded an internal group data transmission and processing agreement within the AHK network, which includes the EU standard contractual clauses. You can view the EU standard contractual clauses at https://eur‑lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de.

3. Cookies

In addition to the cookies by Piwik described in Part A, the following cookies are set by this local website:

Outlook: If you use features on our Website that are provided via Microsoft Outlook or Microsoft 365, such as calendar bookings, embedded forms, etc., this is a service provided by Microsoft Corporation (hereinafter “Microsoft”) and embedded into our Website. Microsoft sets the following cookies on your device:

From the overview, it follows that some cookies are deleted after your browser session ends. In addition, some cookies are so‑called “necessary cookies”: these are required so that our Website functions and displays correctly.

The legal basis for setting these cookies is your consent under Article 6(1) sentence 1 lit. a) GDPR, except for necessary cookies, which may be set under Article 6(1) sentence 1 lit. f) GDPR on the basis of our legitimate interest, as these cookies are required forthe  proper functioning of the Website. Setting the cookie is also based on § 25 para. 2 no. 2 TDDG, which states that storing information in your device or accessing information already stored on your device is strictly necessary to provide a digital service explicitly requested by you, our Website. Further information on data processing by Microsoft can be found in the Microsoft privacy statement.

YouTube: Our Website embeds videos hosted on the platform “YouTube”. This is a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “YouTube”). When you visit our Website in which a YouTube video is embedded, YouTube stores cookies and similar technologies on your device in order to collect visitor information:

From the overview, it follows that some cookies are deleted at the end of your browser session; these are so‑called “session cookies.”

The legal basis for setting these cookies is your consent under Article 6(1) sentence 1 lit. a) GDPR. Further information on data processing by YouTube can be found in Google’s privacy policy: How Google uses cookies – Privacy Policy & Terms of Service – Google.

4. Social Media Button:

On our Website, you will find social media buttons for the following social networks:

i. LinkedIn

Operator of the social media button is LinkedIn Ireland Unlimited Company (hereinafter “LinkedIn”), Wilton Place, Dublin 2, Ireland. If you click the social media button, and your browser connects to LinkedIn’s servers, your personal data will be transferred to LinkedIn. If you are logged into your LinkedIn account while visiting our Website, LinkedIn may assign this information to your personal LinkedIn account. Information about the processing of your personal data by LinkedIn can be obtained from LinkedIn’s privacy policy at www.linkedin.com/legal/privacy‑policy. The legal basis for your use of the social media button is, under Article 6(1), sentence 1 lit. a) GDPR, your consent.

ii. YouTube‑videos

If we embed YouTube videos on our website, they are hosted on the servers of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “YouTube”). We have embedded the videos using so‑called “enhanced privacy settings”. This means that your personal data are not transmitted to YouTube simply by visiting our Website. Only when you actively click the video to play it are your personal data—in the form of server log files and cookie IDs—transmitted to YouTube, and only at that moment are YouTube cookies set.

This transmission happens regardless of whether you have a Google user account or not. If you are logged into a Google account while visiting our Website, this data will be associated with your account. If you do not want this association, you must log out of your Google account before activating the video. Information about the processing of your personal data by YouTube can be found in the YouTube / Google privacy information.

iii. Facebook

Operator of the social media button is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. If you click the social media button while you are logged into your Facebook account, Facebook may associate your usage with your user account. Further information about handling personal data by Facebook in relation to your use can be found in Facebook’s privacy policy.

iv. Instagram

Operator of the social media button which shows a camera icon is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland (hereafter “Instagram”). If you click the social media button, your browser will establish a direct connection to Instagram’s servers and your personal data will be transmitted. If you are logged into your Instagram account while visiting our Website, Instagram will link your visit to our site with your account. Information on data processing by Instagram can be found in Instagram’s privacy information: https://privacycenter.instagram.com/policy.

v. X

Operator of the social media button “X” is Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland (hereinafter “X”). If you activate the re‑tweet button, your personal data will be transmitted to X. If you are logged into your X account while visiting our Website, X may assign this information to your account. More information on data processing by X can be found in X’s privacy information.

vi. Xing

Operator of the Xing social media button is New Work SE (hereinafter “XING”), Am Strandkai 1, 20457 Hamburg, Germany. If you click the XING button, your browser connects with Xing’s servers. Your personal data will be transferred to Xing. If you are logged into your Xing account while visiting, Xing may attribute this data to your Xing account. Information on data processing by Xing can be found in Xing’s privacy policy at www.xing.com/privacy.

5. Support for Expansion Abroad – Appointment Booking Option at a Local AHK

i. Data Categories and Description of Data Processing

If you have used the “Support for Expansion Abroad” offering on the AHK.de Website, entered your personal data there and are now forwarded via the appointment link to our Website, then we process your personal data in order to offer you an appointment with a suitable contact person. For this purpose we process the following categories of data:

• Your first and last name,
• Your business email address,
• The rough background information you provided, such as region, industry and desired service, and
• Date and time of the appointment you selected.

If you also provided the following voluntary personal data on the AHK.de website, such as

• Your business phone number,
• Company name, company size, especially number of employees, and
• Questions and comments which you may enter in a free‑text field, then we also process these.

ii. Legal Basis and Purpose of Data Processing

The legal basis for processing the fields originally marked as mandatory together with the date and time of your desired appointment is, under Article 6(1) sentence 1 lit. b) GDPR, your request addressed to us.

The legal basis for data you provide voluntarily (not mandatory) is your consent under Article 6(1) sentence 1 lit. a) GDPR. The voluntarily provided information serves to give us a more complete picture of your membership (or situation).

iii. Duration of Storage

Your personal data are processed for the duration of the expansion support.

iv. Recipients

The employees of AHK who are tasked with responding to your inquiry will have access to your personal data. It may also happen that employees of DIHK DEinternational GmbH and/or other AHK offices receive access to your personal data. For this purpose, we have concluded an internal group data transfer and processing agreement within the AHK network, which includes the EU standard contractual clauses. You can view those clauses at https://eur‑lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de.

II. Locally Applicable Data Protection Law:

Vietnam: Decree 13/2023/ND‑CP of the Government on the Protection of Personal Data of 17 April 2023

AHK Vietnam (Delegation): pdp@vietnam.ahk.de