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Privacy Policy

Effective date: 18 July 2026 · Last updated: 18 July 2026

This policy explains what personal data Tiny Circle collects, why, and what rights you have over it. It’s written to align with Vietnam’s Personal Data Protection Law (Law No. 91/2025/QH15) (“PDPL”), in force since 1 January 2026.

On this page

  1. 1. Who is responsible for your data
  2. 2. Who this policy covers
  3. 3. What personal data we collect
  4. 4. Consent and legal basis
  5. 5. Why we use your data
  6. 6. Surveys, rewards and marketing
  7. 7. Who we share data with
  8. 8. International transfer of data
  9. 9. Your rights
  10. 10. Children's data
  11. 11. How long we keep data
  12. 12. Security
  13. 13. Cookies and tracking
  14. 14. Changes to this policy
  15. 15. Contact and complaints

1. Who is responsible for your data

Tiny Circle (“Tiny Circle”, “we”) is an independent service operated from Ho Chi Minh City, Vietnam, and is responsible for the personal data described in this policy. A Vietnamese business registration is in progress; this policy will be updated with the registered company name once it is complete.

Contact for data protection matters: privacy@tinycircle.vn

2. Who this policy covers

This policy applies to parents and users of Tiny Circle and to providers who list services with us. It also explains how we handle the limited information about a child that a parent may choose to share.

3. What personal data we collect

From parents and users, when you create an account: your name, email address, and login credentials (password). If you choose to add them: your city/area and your child’s age group, to help us show you more relevant services.

When you use the Platform: any reviews or comments you post, enquiries and messages you send to providers, survey responses, providers you save, and basic technical/usage data (like device type and how you use the app).

Limited information about a child: only what a parent chooses to share (for example, an age range or specific needs), kept to the minimum needed to help match services. We don’t ask for more than necessary, and we never collect data directly from a child.

From providers: business/provider name, contact person, email, phone, service category, address/location, and a description of their service — plus, if provided, website, Facebook page, certifications, business registration number, and any identity-verification data used to check the information they’ve submitted.

4. Consent and legal basis

We rely on your consent, and where applicable other lawful bases under the PDPL. Your consent is voluntary, specific, informed, and given separately for each purpose — we don’t bundle unrelated purposes, pre-tick boxes, or treat silence as agreement, and we keep a record of your consent. You can withdraw consent at any time (see Section 9); this won’t affect anything we did with your data before you withdrew it.

Marketing and paid surveys always use a separate, explicit opt-in (see Section 6).

5. Why we use your data

  • To create and run your account;
  • To help you discover, compare and connect with providers and institutions — when you send an enquiry, we share what’s needed with that provider;
  • To verify providers and process provider fees;
  • To respond to your enquiries and account questions;
  • With your separate consent, to invite you to surveys, share anonymised, aggregated insights with brand partners, and send marketing;
  • To keep the Platform safe, prevent fraud and abuse, and meet our legal record-keeping obligations.

6. Surveys, rewards and marketing

Where you opt in, we may invite you to answer surveys and earn rewards. Any data shared with brand partners from surveys is anonymised and aggregated — brand partners never receive data that identifies you by name, unless you give separate, specific consent for that. You can opt out at any time.

7. Who we share data with

  • Providers — only the information needed to respond to your enquiry;
  • Service providers who work for us — hosting, IT, payment processing, and identity-verification vendors, all under confidentiality obligations;
  • Authorities — where required by Vietnamese law.

We never sell your personal data.

8. International transfer of data

Some of the services we use to run Tiny Circle (for example, our website hosting) may store or process data on servers located outside Vietnam. Where this involves personal data of people in Vietnam, we apply the safeguards and complete the assessments required under the PDPL for cross-border transfers.

9. Your rights

Under the PDPL, you can: access your data; correct it; delete it; withdraw consent; object to or restrict certain processing; request a copy; and lodge a complaint. To use any of these rights, email privacy@tinycircle.vn — we’ll respond within the time required by law.

10. Children’s data

Tiny Circle is for parents and guardians. We don’t knowingly collect personal data directly from a child. Where a parent shares limited information about a child, we treat it with extra care and only use it for the purpose the parent gave it to us. A parent can ask us to review, correct or delete this information at any time by emailing privacy@tinycircle.vn, and we will action it within the time required by law.

11. How long we keep data

We keep personal data only as long as we need it for the purposes above, and to meet Vietnamese legal retention requirements (for example, e-commerce transaction and tax records, which must be kept for a set number of years). After that, we delete or anonymise it.

Enquiries and messages. When you send an enquiry to a provider, we keep a record that you contacted them, and the message you sent. We erase the content of the message after 12 months. We keep the record that the enquiry happened, because it is what allows you to leave a review of that provider, and it contains no message content. You can ask us to erase a message sooner at any time — see Section 9.

12. Security

We apply organisational and technical measures to protect personal data. No system is perfectly secure, but we work hard to protect your information, and we’ll notify you and the relevant authorities of a breach where required by law.

13. Cookies and tracking

We use cookies and similar technologies for essential functionality and, with your consent, analytics.

14. Changes to this policy

We may update this policy. We’ll post the new version here with an updated date, and ask for fresh consent where the law requires it.

15. Contact and complaints

Tiny Circle · Ho Chi Minh City, Vietnam · privacy@tinycircle.vn. You also have the right to complain to the competent Vietnamese data-protection authority.

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