Privacy Policy
Last updated: September 2026
This is a draft template prepared for review by Horus's legal counsel before publication. It is not final legal advice and must be verified against current Vietnamese law and Horus's actual data practices before go-live.
Horus Co., Ltd ("Horus", "we", "us", or "our") is a Clinical Research Organization (CRO) providing clinical trial management, consulting, outsourcing, medical communications, and real-world data science services. This Privacy Policy explains how we collect, use, disclose, and protect personal data obtained through this website (the "Site"), in accordance with Vietnam's Law on Personal Data Protection (Law No. 91/2025/QH15, effective 1 January 2026) and its guiding decrees, which supersede the framework previously set out in Decree No. 13/2023/NĐ-CP.
1. Who We Are
Horus Co., Ltd is the data controller responsible for personal data collected through this Site.
Registered offices: Room 1901, 19th Floor, Saigon Trade Center, 37 Ton Duc Thang Street, Saigon Ward, Ho Chi Minh City, Vietnam; and Floor 14, Vinaconex 9 Building, 34 Lang Ha Street, Ba Dinh District, Hanoi, Vietnam.
Contact: info@horus.vn · +84 8 3526 8588.
2. Scope — Website Visitors vs. Clinical Trial Participants
This Policy applies only to personal data collected through this Site (e.g., visitors, prospective clients, and business contacts who use our contact or document-download forms). It does not apply to personal data of clinical trial subjects/patients, which Horus processes as a data processor on behalf of study sponsors under separate clinical trial agreements, informed consent forms, and Good Clinical Practice (GCP) requirements issued by the Ministry of Health. If you are a trial participant, please refer to the informed consent form and privacy notice provided by the specific study sponsor or investigator site.
3. Personal Data We Collect
Depending on how you interact with the Site, we may collect:
- Data you provide directly: full name, business email address, company/organization, service of interest, and message content (contact form); full name and business email address (document download form).
- Data collected automatically: IP address, approximate location, browser/device information, and usage data (pages visited, referrer, time on page), collected via server logs and, where enabled, Google Analytics (GA4).
- Cookies and similar technologies: see Section 6 below.
We do not knowingly collect sensitive personal data (e.g., health data) through this Site.
4. Purposes and Legal Basis for Processing
- Responding to inquiries and providing requested documents — based on your consent given when submitting a form, and to take steps prior to entering into a contract at your request.
- Operating, securing, and improving the Site (e.g., rate-limiting, spam/bot prevention, diagnosing technical issues) — based on our legitimate interest in keeping the Site secure and functional.
- Website analytics — based on your consent, where analytics cookies are used.
- Complying with legal obligations, including requests from competent Vietnamese authorities.
Where processing is based on consent, you may withdraw your consent at any time by contacting us using the details in Section 11, without affecting the lawfulness of processing carried out before withdrawal.
5. How We Share Your Personal Data
We do not sell your personal data. We may share personal data with:
- Email/SMTP service providers, used solely to deliver your inquiry or requested document to our team.
- Hosting and infrastructure providers, who process data on our behalf under confidentiality obligations.
- Google Analytics (GA4), for aggregated, privacy-respecting website usage analysis, where enabled.
- Competent state authorities, where required by Vietnamese law (e.g., the Department of Cybersecurity and Hi-Tech Crime Prevention, Ministry of Public Security).
6. Cookies and Similar Technologies
The Site may use strictly necessary cookies (required for core functionality) and, where enabled, analytics cookies (Google Analytics) to understand how visitors use the Site. Where required by law, we will request your consent before setting non-essential cookies and provide a way to manage your preferences.
7. Cross-Border Data Transfer
Some service providers referenced above (e.g., Google Analytics) may process data on servers located outside Vietnam. Where we transfer personal data outside Vietnam, we do so in accordance with the cross-border data transfer requirements under Vietnamese personal data protection law, including completing any required impact assessment dossier.
8. Data Retention
We retain personal data collected through this Site only for as long as necessary to fulfil the purposes described in this Policy, to comply with our legal, accounting, or reporting obligations, or to resolve disputes, after which it is securely deleted or anonymized.
9. Data Security
We apply reasonable technical and organizational measures — including rate limiting, anti-spam verification, encrypted transmission (HTTPS), and access controls — to protect personal data against unauthorized access, loss, misuse, or disclosure.
10. Your Rights
Subject to applicable law, you have the right to: be informed about the processing of your personal data; access, rectify, or request deletion of your personal data; restrict or object to processing; withdraw consent at any time; request data portability; and lodge a complaint with the competent Vietnamese data protection authority. To exercise these rights, contact us using the details in Section 11.
11. Contact Us
For any questions about this Privacy Policy or to exercise your data protection rights, please contact: info@horus.vn or +84 8 3526 8588.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The "Last updated" date at the top of this page indicates when this Policy was last revised. Material changes will be notified through this Site.