The Vietnam Addendum to the 3M Global Privacy Policy

This addendum supplements, details or modifies the 3M Global Privacy Policy in accordance with the applicable local data privacy law, its implementing rules and regulations and related issuances of the local data privacy regulator (collectively referred to herein as “Law”).

This addendum applies to the processing of personal data by 3M Vietnam Limited (“3M” or “we” hereinafter). For this purpose, the term “processing” shall include, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of personal data.

  • Personal data

    Vietnam law defines personal data as information associated with the identification of a specific person.

    The personal data collected by 3M may include, but not limited to, the following:

    • name, title, address;
    • personal identification and/or passport number;
    • telephone number;
    • email address and online passwords;
    • medical records and biometrics;
    • records of communications with 3M;
    • responses to market surveys and contests conducted by 3M or on its behalf;
    • credit card or debit card information;
    • camera or video footage that identifies individuals (including CCTV footage) installed at some parts of 3M’s premises as part of its security infrastructure;
    • username, password and other identifiers when you register at 3M’s website;
    • other information associated with the identification of a specific individu.
  • Collection, Purpose of Collection and Processing of Personal Data

    Personal data will, generally, only be collected and used for the primary purposes of:

    • communicating with employees, customers, contractors, suppliers, agents or any other individuals;
    • conducting, improving, maintaining and developing a business relationship and/or for employment purposes;
    • general HR administration and information required for the management of the employment relationship;
    • processing, servicing or enforcing transactions and sending related communications;
    • identifying and verifying individuals that have been supplied with any 3M services or products;
    • administering customer orders or managing projects;
    • responding to an individual’s queries;
    • administering contests or market surveys conducted by 3M or on 3M’s behalf;
    • marketing (such as providing individuals with information about 3M products and promotional notices and offers);
    • processing your purchase, application, inquiry or request;
    • ensuring IT security and resource management;
    • ensuring site security;
    • compliance with applicable laws and regulations of regulatory authorities and enforcement agencies;
    • administrative purposes such as billing, payment and debt collection;
    • responding to any claim and/or legal process; and
    • improving 3M’s website.
  • Disclosure

    3M discloses personal data:

    • for the primary purpose for which it was collected; or
    • for purposes that a reasonable person will consider appropriate in the circumstances; or
    • where the individual has consented; or
    • for direct marketing by 3M where consent has been given, but individuals will be given the opportunity to opt out of such direct marketing. 3M includes its contact details in any direct marketing; or
    • where permitted by law;
    • to 3M’s parent, related, affiliate and/or associate company;
    • in any court of law or any relevant party in connection with any claim or legal proceedings, legal firms and/or advisors, debt collection agencies, credit reporting agencies and/or credit providers;
    • to any payment agencies including, but not limited to, financial institutions for purposes of maintaining financial records, assessing or verifying credit, and facilitating payment;
    • regulatory authorities and enforcement agencies;
    • third party service providers, consultants, insurers, underwriters, auditors and advisors as well as their respective agents and/or contractors on a need to know basis; and
    • any actual or potential assignee, transferee or acquirer of any of 3M’s business in connection with any corporate exercise.

    3M does not disclose your personal data for any secondary purposes unless your consent has been previously obtained in accordance with law.

    3M will not sell or license any personal data that it collects from an individual.

    In situations where 3M processes personal data outside reasonable expectations, 3M will require your consent prior to processing.

  • Cross-border disclosure

    Any personal data provided to 3M may be transferred to, stored by or disclosed to an overseas recipient. For example, 3M may use a server hosted overseas to store data, which may include your personal data.

    Your personal data may also be processed by employees or by other third parties operating outside of Vietnam in countries like the United States of America or in the European Union, who work for 3M, or by the representatives and employees of 3M’s parent company and affiliates.

    3M will take reasonable steps, in the circumstances, before your personal data is disclosed to an overseas recipient, to ensure that the overseas recipient does not breach privacy laws in relation to your personal data.

  • Data breach

    Where a suspected data breach has occurred, 3M will act in accordance with its data breach response plan. In the event that 3M has determined that a data breach has occurred, we will notify the local data privacy regulator and affected data subject (s) in accordance with law.

  • Anonymity

    3M gives individuals the option not to identify themselves when dealing with it, where practicable. However, if you do not provide us with the personal data that we request, our ability to handle your inquiry, request, complaint or application may be diminished.

  • Consent and limitation in the processing of personal data

    You may choose whether or not to provide your personal data, and, if already provided, you may choose to exercise your right to object, block, or remove such personal data as provided by law. If you would like to exercise your right to object, block, or remove your consent, please contact 3M using the contact details below.

    In this case, however, we may not be able to adequately provide you the assistance or services you requested.

    When you object, block or remove your consent, 3M shall no longer process your personal data, except in cases allowed or required by law.

    If you would like to update, correct or access your personal data, please contact us using the contact details below.

  • Inquiries and Complaints

    If you have any queries or concerns about 3M’s privacy policy, this addendum or about our use of your personal data, you may write to us using the following contact details:

          Email: vnprivacy@mmm.com

          3M Vietnam Limited
          Attn: Data Protection Officer
          1060 Nguyen Van Linh, Tan Phong Ward
          District 7, Ho Chi Minh City
          Vietnam