PERSONAL DATA PROTECTION POLICY

Nully Co., Ltd. respects your personal data.
This page explains what we collect, why, where it is stored and what rights you have.

Effective 9 October 2026 · Version 1.0

1. Scope

The nullylab.com website and its forms: Talent application (audition), Brand · Partner inquiry, Nully global Talent Contest application.
A consent summary appears when you submit a form. That summary and this policy apply together.

Nully Co., Ltd. · Hanoi, Vietnam (NULLY 8-floor building).
Personal data contact: [email protected]. The personal data protection team receives requests at the same address.

Talent application: full name, date of birth, phone number or Zalo, email, field of application, video link, message.
Brand · Partner inquiry: company name, contact person, email, phone number, area of interest, message.
Talent Contest: full name, year of birth, phone number (Zalo), place of residence, social media platform and account ID, video link (if any), self-introduction (if any).
Recorded automatically on submission: time of submission, language, page, traffic source (UTM), access log (IP), consent version and time.
Ly guide character (chat box on the contest page): the messages you type and connection log (partial IP). Phone numbers and emails are masked automatically; please do not enter personal details.
We do not collect payment information. Contest videos that show a face are used only for judging and record keeping and are not analysed with facial recognition technology.

Receiving applications and verifying identity.
Evaluation and judging, announcing results and sending feedback sheets.
Contacting winners and informing selected applicants of class and training schedules.
Registering a Talent ID and managing later development stages.
Responding to brand and partner requests.
Sending information about KOC programs with Korean brands, only if you ticked the separate consent. You can opt out at any time.
Meeting legal obligations and keeping proof of consent.

Processing is based on your consent under Vietnam's Law on Personal Data Protection (Law No. 91/2025/QH15) and Decree 356/2025/ND-CP.
Consent is separated by purpose. No box is pre-ticked. You may withdraw consent at any time; withdrawal does not affect processing already carried out.

Talent application: until the related evaluation and training ends, then up to 24 months.
Brand · Partner inquiry: up to 12 months after the exchange ends.
Talent Contest: until the contest ends, then up to 12 months.
Ly chat logs: deleted automatically after 30 days.
Proof of consent (version, time): kept for the same period as legal evidence.
If you ask for earlier deletion, we delete everything except what the law requires us to keep.

Form data is stored on the cloud infrastructure of Cloudflare, Inc. (USA), with servers in several countries including Singapore and the USA.
Form notifications are sent through Google LLC's Gmail (USA).
Nully's head office in Korea may access the data to run the programs.
Under Article 20 of the Law on Personal Data Protection this is a cross-border transfer. Nully follows the statutory procedure and applies equivalent safeguards.

We do not sell personal data.
Apart from the processors in section 7 (Cloudflare, Google), we do not pass data to third parties unless required by law.
Appearing in a sponsor's or partner's advertising happens only with your separate consent.

Anyone under 16 needs the consent of a parent or legal guardian.
Publishing photos or videos of a child aged 7 or older needs the consent of both the child and the guardian.
We confirm these consents at the prize-contact or content-production stage.

Access, correction, deletion, restriction, objection and withdrawal of consent.
A copy of your data.
Send requests to [email protected]. We reply within 2 working days and may ask you to verify your identity first.
You may lodge a complaint with the competent personal data protection authority in Vietnam.

The whole website uses HTTPS.
Access to form data is limited to staff in charge.
If we detect a data breach, we notify the competent authority and affected people as required.

The website uses no tracking cookies and no third-party analytics or advertising tools.
Only one value (nully-lang) is stored in your browser to remember your language.

When we change it, we publish the new version on this page with its effective date.
Important changes are announced on the website or by email if you have given one.