Privacy Policy
for Sosene
Last updated: 5 October 2026
Effective date: 5 October 2026
This Privacy Policy explains how Sosene Company Limited (“Sosene”, “we”, “our” or “us”) collects, uses, shares and protects personal data when you visit sosenesoftware.com (the “Website”), contact us, or register for an event we promote. Please read it together with our Cookie Policy.
1. Who is responsible for your data
The data controller is Sosene Company Limited (enterprise code 0316544687), F1.5 – 1st Floor, SABAY Building, 38 Cong Hoa Street, Ward 4, Tan Binh District, Ho Chi Minh City 700000, Vietnam.
You can reach our Data Protection Officer at marketingteam@sosenesoftware.com.
2. Personal data we collect
2.1 Data you give us
- Consultation and contact forms: first and last name, company or organisation, work email, phone number, the service you are interested in, company size and project timeline (both optional), your message, and the time you accepted this policy.
- Event registration forms: name, company, email, phone and the event you are registering for.
- Emails and calls you send or make to us, and anything you choose to include in them.
2.2 Data collected automatically
- Technical data such as IP address, browser, device type and the pages you visit, recorded by our hosting provider’s security and server logs.
- Analytics data (pages viewed, approximate location, referring website and campaign tags, Google Analytics client and session identifiers), collected through cookies or similar technologies as described in the Cookie Policy and subject to your cookie choices.
- Your cookie consent choice and its date, so we can respect it on later visits.
- If you accept advertising cookies, Apollo.io may identify the company associated with your visit.
2.3 Data from other sources
We may add publicly available business information about you or your company (for example job title, company size or industry) from business-data providers such as Apollo.io and from public sources such as company websites and LinkedIn.
We do not ask for sensitive personal data (for example health, political opinions or biometric data). Please do not include it in messages.
3. How we use your data and our legal basis
| Purpose | Data used | Legal basis |
|---|---|---|
| Answering your enquiry, preparing a proposal and arranging a consultation | Form data, emails | Your consent given when you submit the form; steps you request before entering into a contract |
| Managing our sales relationship with you in our CRM (Microsoft Dynamics 365 Sales) | Form data, business information, campaign source | Your consent; our legitimate interest in following up business enquiries |
| Measuring and improving the Website (Google Analytics) | Analytics data | Your consent where required (for example in the EU/UK); elsewhere our legitimate interest, and you can refuse analytics cookies at any time |
| Sending marketing emails about our services | Name, email, company | Your consent; you can unsubscribe at any time |
| Protecting the Website and forms against spam, fraud and abuse (Google reCAPTCHA, Akismet, security logs) | Technical data, form content | Our legitimate interest in keeping the Website secure |
| Complying with legal obligations and defending legal claims | Any relevant data | Legal obligation; legitimate interest |
If we want to use your data for a purpose not listed here, we will tell you first and, where required, ask for your consent.
4. Automated processing and AI
When an enquiry reaches our CRM, Microsoft Dynamics 365 Sales features, including AI-based sales agents, may research publicly available information about your company and summarise or prioritise the enquiry for our sales team. These tools support our staff; they do not make decisions that have legal or similarly significant effects on you, and a member of our team reviews every enquiry.
5. Who we share your data with
We do not sell your personal data. We share it only with the service providers below, who process it on our behalf under contracts that require them to protect it and use it only on our instructions, and where the law requires it.
| Provider | What they do for us | Where data may be processed |
|---|---|---|
| Microsoft (Microsoft 365, Dynamics 365 Sales) | Business email; CRM where enquiries are stored and managed, including AI sales features | Asia Pacific data centres for Dynamics 365; Microsoft’s global infrastructure for email |
| Google (Google Analytics, Google Tag Manager, reCAPTCHA) | Website analytics; tag management; spam protection on forms | United States and other countries where Google operates |
| Elementor (Site Mailer, Cookie Consent) | Delivering the emails our Website sends (form notifications and confirmations); recording cookie consent choices | Countries where Elementor and its service providers operate, outside Vietnam |
| Apollo.io | Identifying visiting companies (only with advertising consent); business contact data | United States |
| AZDIGI Corporation | Website hosting, including stored form submissions and server logs | Vietnam |
| Automattic (Akismet) | Spam filtering of comments posted on the Website | United States |
We may also disclose data to competent authorities when the law requires it, to enforce our agreements, or to a buyer or successor in a merger, acquisition or sale of assets, who will be bound by this policy.
6. Transfers outside Vietnam
Some of the providers above store or access data outside Vietnam, including in Singapore and other Asia Pacific countries, the European Union and the United States. We put safeguards in place before personal data is transferred abroad, including contractual commitments from the recipient and, for data of individuals in the EU/UK, the European Commission’s standard contractual clauses or another recognised mechanism. We handle these transfers in accordance with Vietnamese personal data protection law, including its requirements for transferring personal data abroad.
7. How long we keep your data
| Data | Retention |
|---|---|
| Enquiries and leads that do not become customers | 24 months after our last contact with you, then deleted or anonymised |
| Customer and contract records | For the duration of the relationship and afterwards as long as required by accounting, tax and other laws |
| Google Analytics user and event data | Up to 14 months; aggregated reports may be kept longer |
| Cookie consent choice | 180 days, after which we ask again |
| Submissions held as suspected spam | 90 days |
8. Your rights
Depending on where you live and the applicable law, including Vietnam’s Law on Personal Data Protection (Law No. 91/2025/QH15) and Decree 13/2023/ND-CP, and the EU/UK GDPR, you may have the right to:
- be informed about how your data is processed;
- access your data and receive a copy of it;
- correct inaccurate data;
- delete your data, or restrict how we use it;
- object to processing, including direct marketing at any time;
- withdraw your consent at any time, without affecting processing that took place before;
- receive your data in a portable format where applicable;
- lodge a complaint with a supervisory authority, such as the Department of Cybersecurity and High-Tech Crime Prevention (A05), Ministry of Public Security, in Vietnam, or your local data protection authority in the EU/UK.
To exercise these rights, email marketingteam@sosenesoftware.com. We may need to verify your identity, and we will reply within the time limit set by applicable law.
9. Cookies
We use cookies and similar technologies for the Website to work, to measure its use and, with your consent, for advertising. You can accept, refuse or customise them in the cookie banner and change your choice at any time through the “Cookie settings” link in the footer. Details are in our Cookie Policy.
10. Security
We use appropriate technical and organisational measures to protect personal data, including encrypted connections (HTTPS), access controls on our systems, certificate-based authentication between the Website and our CRM, and regular review of who can access personal data. No system is completely secure; if a personal data breach occurs we will act promptly and notify the authorities and affected individuals where the law requires it.
11. Children
The Website is intended for businesses and is not directed to children. We do not knowingly collect personal data from children. If you believe a child has given us personal data, please contact us and we will delete it.
12. Changes to this policy
We may update this policy from time to time. We will post the new version on this page with a new “Last updated” date and, where the changes are significant, tell you in a more visible way.
13. Contact us
Sosene Company Limited
F1.5 – 1st Floor, SABAY Building, 38 Cong Hoa Street, Ward 4
Tan Binh District, Ho Chi Minh City 700000, Vietnam
Email: marketingteam@sosenesoftware.com