Skip to main content

Policies Reference for VinGen project

At VinBigData, we take your privacy seriously and it matters to us that you acknowledge the reasons we’re collecting and using information.

By using or accessing our Products and Services in any manner, you confirm that you accept the practices and policies stated in this Privacy Policy.

I. Partners’ information

1. Information VinBigData collects

Your visit to the VinBigData website is private and secure. When you visit the VinBigData website, we do not collect any personally identifiable information (PII) about you, unless you choose to explicitly provide it to us. We do, however, collect some data about your visit to our website to help us better understand public use of the site and provide better services for all partners.

2. How VinBigData collects Information

When you browse through any website, certain information about your visit can be collected. VinBigData uses the Google Analytics programs to collect information automatically and continuously. We use this information to measure the number of visitors to our site and its various sections and to distinguish between new and returning visitors to help make our site more useful to visitors. However, no personally identifiable information (PII) is collected.

The VinBigData staff conducts analyses and reports on the aggregated data from Google Analytics. The reports are only available to VinBigData website managers, members of their Communications and Web Teams, and other designated staff who require this information to perform their duties.

VinBigData also uses online surveys to collect opinions and feedback from a random sample of visitors. VinBigData uses the Google Forms online survey tool to obtain feedback and data on visitors’ experiences on the http://genome.VinBigData.org website. These surveys do not collect PII. Although the survey invitation is presented to a random sample of visitors, it is optional. If you decline the survey, you will still have access to the identical information and resources on http://genome.VinBigData.org site as those who do not take the survey. The survey reports are available only to VinBigData managers, members of the VinBigData Communications and Web Teams, and other designated staff who require this information to perform their duties.

VinBigData retains the data from Google Analytics as long as needed to support the mission of the http://genome.VinBigData.org website.

For more information, please visit VinBigData.

3. How VinBigData Uses Cookies

When you visit any website, its server may generate a piece of text known as a "cookie" to place on your computer. The cookie allows the server to "remember" specific information about your visit while you are connected. The cookie makes it easier for you to use the dynamic features of web pages. Requests to send cookies from VinBigData’s webpages are designed to collect information about your browser session only; they do not collect personal information about you.

There are two types of cookies, single session (temporary) and multi-session (persistent). Session cookies last only as long as your Web browser is open. Once you close your browser, the cookie disappears. Persistent cookies are stored on your computer for longer periods.

How Are Temporary "Session” Cookies Used?

We use session cookies for technical purposes such as improving navigation through our website. These cookies let our server know that you are continuing a visit to our website. The "session" cookie is not permanently stored on your computer. The cookie and the information about your visit are automatically destroyed shortly after you close your browser to end the session.

How Are "Persistent Cookies" Used?

We use persistent cookies to help us recognize new and returning visitors to the VinBigData website. Persistent cookies remain on your computer between visits to the VinBigData website until they expire. We do not use this technology to identify you or any other individual website visitor.

We also use persistent cookies to enable VinBigData’s Google Analytics programs to measure how new and returning visitors use the VinBigData website over time.

4. How we use information VinBigData collects

We use the information we collect from all of our products and services to provide, maintain, protect and improve them, to develop new ones, and to protect VinBigData and our partners. We also use this information to give you tailored offers – like giving you better offers that meet your needs.

When you contact VinBigData, we keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements.

We use information collected from cookies and other technologies to improve your user experience and the overall quality of our products and services.

We might also use your information in the following cases:

  • To develop partnerships
  • Feedback and/or provide relevant information on your requests.
  • For marketing purposes
  • For legal reasons: We will share personal information with companies, organizations or individuals outside of VinBigData if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
    • Meet any applicable law, regulation, legal process or enforceable governmental request.
    • Enforce applicable Terms of Service, including investigation of potential violations.
    • Detect, prevent, or otherwise address fraud, security or technical issues.
    • Protect against harm to the rights, property or safety of VinBigData, our partners or the public as required or permitted by law.

We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

We may share non-personally identifiable information publicly and with our partners for the purpose of showing trends about the general use of our products and services.

5. How Is User's Personal Information Protected?

You do not have to give us personal information to visit the VinBigData website.

If you choose to provide us with additional information about yourself through an e-mail message, form, survey, etc., we maintain the information only as long as needed to respond to your question or to fulfill the stated purpose of the communication.

For further information about VinBigData privacy policy, please contact the VinBigData Senior Official for Privacy at vingen@vinbigdata.org.

6. Disclosure

VinBigData does not disclose, give, sell, or transfer any personal information about our visitors, unless required for law enforcement or by statute.

7. Site Security

VinBigData's website www.genome.VinBigData.org is maintained by the Vingroup Big Data Institute. For site security purposes and to ensure that this service remains available to all partners, we use software programs to monitor traffic to identify unauthorized attempts to upload or change information or otherwise cause damage. In the event of authorized law enforcement investigations, and pursuant to any required legal process, information from these sources may be used to help identify an individual.

II. Personal genetic data

1. Genetic data processing principles

VinBigData complies with personal genetic data protection legislation. According to Recital 34 of General Data Protection Regulations (GDPR), genetic data are defined as personal data relating to the inherited or acquired genetic characteristics of a natural person which result from the analysis of a biological sample from the natural person in question, in particular chromosomal, deoxyribonucleic acid (DNA) or ribonucleic acid (RNA) analysis, or from the analysis of another element enabling equivalent information to be obtained.

VinBigData only processes data if it meets at least one of the following criteria:

  • The data subject has given consent to the processing of his or her personal data for one or more specific purposes;
  • Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
  • Processing is necessary for compliance with a legal obligation to which the controller is subject;
  • Processing is necessary in order to protect the vital interests of the data subject or of another natural person;
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

VinBigData are not responsible for pseudonymizing personal data. VinBigData’s input data providers are liable for personal data pseudonymization so that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

VinBigData relies on the provision that allows us to process personal data based on our legitimate interests, which are to carry out medical research and in providing clinical care.

2. Consent

It is important to note that participant informed consent is fundamental to the VinBigData’s work – and this will not change.

VinBigData is committed to – and will continue to deliver – a workable consent process that allows participants to make informed choices on how their confidential genomic data is used.

3. Information we collect, store, and process about you

We collect, store and process your personal information and this information includes health data from clinical care that has been given to us about your genome sequence data which is obtained after we have processed samples of blood, tissue, and saliva. We also produce interpretation reports once we have analyzed all your information and these reports are provided to your clinical team for review.

4. Keeping data private

Research partners will have restricted access to de-identified datasets which contain only the information they need for their specific and approved research study. From this information they may produce additional research data based on their analysis. Researchers should not be able to work out who this data is about, or even who is participating in the Project, simply by looking at the information in the system. However, any non-trivial piece of health data – even a de-identified report of an appointment booking – could be re-identified by somebody who already has enough information about the individual in question. This is why VinBigData insists all access to its data takes place within their secure environment, where it can be monitored.

No data held by VinBigData will be accessible to other government agencies. In the unusual situation that a request for data is made by a court order then this will be referred to VinBigData's Legal Counsel as promptly as possible so that all representations may be made to the court, for example, to limit the information requested being released. We do not share information with insurance companies.

5. Information that is captured when we are contacted

VinBigData can be contacted by email. When you contact us we may record your details so we can best answer your query and provide you with a response. We will keep a record of these communications in case you contact us again but these records will not be used for other purposes. We review the information we hold and the length of time these are held as part of our records management policy.

We may contact you by post to keep you informed about the Database of Genomics Variants for Vietnamese Population Project or to discuss clinical trials that may be of interest to you. We may use email to do this if you prefer and where you have provided us with your email address.

6. Accessing and updating your personal information

You have the right of access to your personal information; you also have rights to rectify the information or have it erased, and to restrict or object to processing. These rights are subject to various exceptions, including in relation to information processed for research purposes.

VinBigData aims to ensure that we have the most accurate data and up to date information but we do recognize that this may not always be the case. If the information we hold is wrong we strive to give you ways to update it quickly or to request it is deleted. When updating your personal information, we may ask you to verify your identity before we can act on your request.

There may also be situations where we may reject requests that we believe are unreasonably repetitive or require disproportionate technical effort. We may also reject requests that we believe risk the privacy of others and where these circumstances apply we will contact you to discuss our concerns.

Where we can provide information access and correction, we will do so free of charge. In certain cases we may charge reasonable amounts where we believe this is appropriate due to the effort that may be needed to satisfy the request. Again where we believe this is the case we will contact you to discuss the matter further.

Like all organizations we take our data security extremely seriously and therefore we make backups of all our data. This helps to protect the vital data from accidental or malicious destruction. Because of this, after we have deleted information, at your request, we may not immediately be able to delete residual copies from our backup systems. We will confirm to you as part of our discussions how we can address your privacy concerns in this respect.

7. Information security and period of storage

We work hard to protect all data from unauthorized access to or unauthorized alteration, disclosure or destruction of information that we hold. In particular:

  • We encrypt much of the data that we deem important
  • We use access control techniques
  • We restrict access to personal information to only those staff who need to see this information
  • All staff and suppliers who need to access this information are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations.
  • We continually review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.

We store your personal data for no longer than is necessary to carry out our legitimate interests of research. We have implemented appropriate technical and organizational measures to keep your personal data safe and to safeguard your rights and freedoms.

III. When this Privacy Policy applies

Our Privacy Policy applies to all of the products and services offered by VinBigData, and products VinBigData provides on App Store and Play Store, and services offered on other sites (such as our advertising services), but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include VinBigData services, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services.

IV. Changes

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any questions, please contact us via: vingen@vinbigdata.org.