Privacy Policy

1. Key Points

When you use LuminPath:

• We collect only personal data needed to provide and operate the current Services.
• You may sign in using supported methods, including Google Sign-In and Zalo QR code authentication.
• CVs and candidate information may be processed by AI to organize information and assist with candidate-job analysis.
• AI-generated analysis is intended to support recruitment work and does not itself make the final hiring decision.
• We do not currently collect payment or billing information because LuminPath does not currently offer paid features.
• We do not sell personal data.
• You may request access to, correction of, deletion of, or restriction of certain personal data in accordance with applicable Vietnamese law.

2. Personal Data We Collect

The personal data we collect depends on how you use LuminPath.

2.1 Account Information

When you create or use a LuminPath account, we may process information such as:

• Name;
• Email address;
• Account identifier;
• Profile information provided through the selected login method;
• User role and access permissions; and
• Information necessary to create, authenticate, and maintain your account.

We use this information to identify you, allow you to access LuminPath, maintain your account, and protect account security.

2.2 Google Sign-In

LuminPath supports Google Sign-In.

If you choose to sign in using Google, Google may provide us with basic account information that you authorize to be shared, such as:

• Your Google account identifier;
• Name;
• Email address; and
• Profile picture or other basic profile information made available through the authentication process.

We use this information only to authenticate you, create or associate your LuminPath account, and maintain your login session.

Using Google Sign-In does not give LuminPath access to your Gmail messages, Google Drive files, Google Contacts, Google Calendar, or other Google services.

LuminPath does not currently request access to those services through Google Sign-In.

Google's own processing of your information is governed by Google's applicable privacy terms.

2.3 Zalo Authentication

LuminPath also supports login through Zalo, including Zalo-based QR code authentication.

When you use Zalo to authenticate your identity, we may receive:

• A Zalo account identifier; and
• Basic account information made available through the authentication process and authorized by you.

We use this information only to authenticate your identity, create or associate your LuminPath account, and maintain access to the Services.

LuminPath does not use Zalo authentication to access unrelated Zalo content or social activity.

Zalo's own processing of your information is governed by Zalo's applicable privacy terms.

3. Candidate and CV Information

LuminPath processes candidate information as part of its recruitment functions.

Depending on the information contained in a CV or entered into LuminPath, this may include:

• Candidate name;
• Email address;
• Phone number;
• Employment history;
• Education history;
• Skills;
• Professional experience;
• Qualifications and certifications;
• Job-related information; and
• Other professional information contained in the CV or provided for recruitment purposes.

Users should avoid uploading personal information that is not reasonably necessary for recruitment.

Where a user uploads or enters another person's CV or personal data into LuminPath, that information should only be provided where the user is authorized to process it for legitimate recruitment purposes.

4. Job and Recruitment Information

LuminPath may process information created or entered during recruitment activities, including:

• Job titles and job descriptions;
• Job requirements;
• Candidate-job relationships;
• Candidate status;
• Recruitment progress;
• Candidate evaluations or recruitment-related records entered into the Services; and
• Other information necessary to manage the recruitment workflow available in LuminPath.

We process this information only to provide the recruitment functions available through the Services.

5. How We Use Personal Data

We use personal data only for purposes related to operating and providing LuminPath.

These purposes include:

Account and Authentication

To:

• Create and maintain accounts;
• Authenticate users;
• Support Google and Zalo login;
• Manage user permissions; and
• Protect accounts against unauthorized access.

Recruitment Functions

To:

• Store and organize job information;
• Store and organize candidate information;
• Process uploaded CVs;
• Extract and structure job-related information from CVs;
• Associate candidates with relevant job information;
• Track recruitment progress; and
• Support recruitment workflows available within LuminPath.

AI-Assisted Functions

To:

• Parse and structure information contained in CVs;
• Analyze candidate qualifications and professional experience;
• Analyze job requirements;
• Compare candidate information with job requirements; and
• Generate AI-assisted recruitment insights based on the information provided to LuminPath.

Operation and Security

To:

• Operate and maintain the Services;
• Diagnose technical problems;
• Protect accounts and the Services from misuse or unauthorized access;
• Respond to user support requests; and
• Comply with applicable legal obligations.

We do not use personal data for unrelated purposes without an appropriate legal basis or additional consent where required.

6. How LuminPath Uses Artificial Intelligence

Artificial intelligence is used to support specific functions within LuminPath.

For example, LuminPath may process the information contained in a CV together with job information in order to:

• Identify and organize candidate experience, education, and skills;
• Understand relevant job requirements;
• Compare candidate qualifications with job requirements; and
• Generate recruitment-related analysis or recommendations.

The information processed by AI may include personal data contained in CVs or recruitment records when such information is necessary to perform the requested function.

AI Results Are Assistive

AI-generated results are intended to assist users with recruitment work.

AI-generated analysis may be incomplete or inaccurate and should be reviewed together with the original candidate information and other relevant factors.

LuminPath's AI-generated analysis does not itself constitute a final hiring or employment decision.

Human users remain responsible for recruitment and employment decisions made using information available through LuminPath.

7. Information Collected Automatically

When you use LuminPath, certain technical information may be generated or recorded as part of operating and securing the Services.

This may include:

• IP address;
• Browser and device information;
• Login and authentication records;
• Date and time of access;
• Basic system activity;
• Error or diagnostic information; and
• Security-related records such as failed login attempts.

We use this information only where necessary to operate, secure, troubleshoot, and maintain LuminPath.

We do not use this information for behavioral advertising.

8. Cookies and Similar Technologies

LuminPath may use cookies, local storage, or similar technologies that are necessary for the operation of the Services.

These technologies may be used to:

• Keep users signed in;
• Maintain authenticated sessions;
• Remember necessary service settings;
• Protect account security; and
• Ensure that the Services function correctly.

LuminPath does not currently use these technologies for third-party behavioral advertising.

9. How We Share Personal Data

We do not sell personal data.

Personal data may be disclosed only where necessary for the operation of LuminPath or where required by law.

9.1 Authorized Users

Candidate and recruitment information may be accessible to users who have the appropriate permissions within LuminPath.

Access is limited according to the user's role and the recruitment functions available to that user.

Users must only access and use candidate information for legitimate recruitment purposes.

9.2 Authentication Providers

When you use Google or Zalo authentication, information necessary to complete the authentication process is exchanged with the relevant authentication provider.

Google and Zalo process information under their own privacy policies and terms.

9.3 Technical Service Providers

We may use technical service providers that support the operation of LuminPath, such as infrastructure, storage, security, or AI-processing services.

Where such providers process personal data on our behalf, they are permitted to process that information only as necessary to provide their services to LuminPath and subject to applicable data-protection requirements.

9.4 Legal Requirements

We may disclose personal data where required or permitted by Vietnamese law, including where necessary to:

• Comply with a lawful request from a competent authority;
• Comply with applicable legal obligations;
• Protect the security and integrity of LuminPath;
• Investigate unlawful or unauthorized activity; or
• Protect the lawful rights and interests of LuminPath, our users, candidates, or other persons.

10. International Processing of Personal Data

Certain technical infrastructure or service providers used to operate LuminPath may process personal data outside Vietnam.

Where the use of such services constitutes a cross-border transfer of personal data under Vietnamese law, LuminPath will apply the measures and procedures required by applicable Vietnamese personal data protection laws.

We do not transfer personal data internationally for unrelated purposes.

11. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected or processed.

This may include the period necessary to:

• Maintain a user account;
• Provide the Services;
• Maintain candidate and recruitment records required by users;
• Protect system security;
• Resolve disputes;
• Respond to legitimate data requests; or
• Comply with applicable legal obligations.

When personal data is no longer necessary for the applicable purpose, we will delete, anonymize, or otherwise handle it in accordance with applicable law.

If you request deletion of your personal data, we will process the request in accordance with applicable Vietnamese law, subject to any lawful reason that requires or permits us to retain certain information.

12. Your Privacy Rights

Subject to applicable Vietnamese law, you may have rights concerning your personal data, including the right to:

Be Informed

You may request information about how your personal data is processed.

Give or Withdraw Consent

Where processing is based on your consent, you may give, refuse, or withdraw that consent in accordance with applicable law.

Withdrawal of consent does not automatically affect processing that lawfully occurred before the withdrawal.

Access Your Personal Data

You may request access to personal data relating to you that we process.

Correct Your Personal Data

You may correct inaccurate information or request that we correct information relating to you.

Request Deletion

You may request deletion of your personal data where applicable.

Request Restriction of Processing

You may request that certain processing of your personal data be restricted where permitted by law.

Object to Processing

You may object to certain processing activities where applicable.

Exercise Other Rights Available Under Vietnamese Law

You may also exercise other rights available to personal data subjects under applicable Vietnamese personal data protection laws, including submitting complaints or requests to competent authorities where appropriate.

To exercise a privacy right, contact us using the details in Section 17.

We may need to verify your identity before responding to certain requests in order to protect personal data from unauthorized access or deletion.

13. Consent and Your Choices

Where Vietnamese law requires consent for processing personal data, we will seek consent in a clear and identifiable manner.

Consent will relate to the relevant processing purpose and will not be inferred merely from silence or failure to respond.

You may withdraw consent where permitted by law.

Certain processing may still be carried out without consent where expressly permitted or required by applicable law.

If withdrawing consent makes it impossible for LuminPath to process information that is necessary to provide a particular function, that function may no longer be available to you.

14. Data Security

We use reasonable technical, organizational, and administrative measures designed to protect personal data against:

• Unauthorized access;
• Unauthorized disclosure;
• Loss;
• Alteration;
• Misuse; and
• Destruction.

Access to personal data is limited according to the operational needs and permissions associated with the Services.

However, no system connected to the Internet can be guaranteed to be completely secure. Users should also take appropriate measures to protect their accounts and authentication credentials.

15. No Payment Information

LuminPath does not currently offer paid features.

Accordingly, we do not currently collect payment card information, billing information, or payment transaction information through LuminPath.

16. Changes to This Privacy Policy

We may update this Privacy Policy where necessary to reflect changes to the Services, our data-processing practices, or applicable legal requirements.

If we make material changes, we will update the "Last Updated" date at the top of this Privacy Policy and provide additional notice where required by law.

The current version of the Privacy Policy will remain available through LuminPath.

17. Contact Us

If you have any questions about this Privacy Policy or would like to exercise your privacy rights, please contact us at:

Email: contact@linxhk.ai

Please describe your question or request clearly. For your security, do not include passwords or other sensitive information in your initial email.