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.
[Company legal name — add once incorporated] (“Tiny Circle”, “we”), Ho Chi Minh City, Vietnam, is responsible for the personal data described in this policy.
Contact for data protection matters: privacy@tinycircle.vn
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.
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.
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).
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.
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.
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.
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 review, correct or delete this information at any time.
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.
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.
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.
[Company legal name] · Ho Chi Minh City, Vietnam · privacy@tinycircle.vn. You also have the right to complain to the competent Vietnamese data-protection authority.