VCI Legal – January 27, 2026

1. Regulatory background and enforcement context.

Vietnamese authorities have recently taken enforcement action against VNG Corporation, the operator of the Zalo platform, and TikTok for violations relating to the collection and use of users’ personal data. The sanctions were imposed by the National Competition Commission under the Ministry of Industry and Trade, pursuant to the Law on Protection of Consumer Rights and related implementing regulations.

This case reflects a broader regulatory trend in Vietnam toward stricter supervision of digital platforms whose business models rely heavily on large-scale data collection and monetisation.

2. Findings on unlawful consent and user autonomy.

The regulator determined that both platforms failed to establish consent mechanisms that meet the legal requirements of being informed, specific, and voluntary. Users were not given meaningful choices regarding the scope of personal data collected or the purposes for which such data would be processed, particularly in relation to advertising and commercial exploitation.

In practice, consent was structured in a manner that effectively required users to accept all data processing conditions as a prerequisite for continued use of the service, calling into question the legal validity of such consent under Vietnamese law.

3. Contractual and transparency deficiencies.

With respect to Zalo, the authority identified shortcomings in the platform’s terms of service, including the inclusion of contractual provisions considered invalid and the absence of clear information on the effective date and legal basis of data processing terms.

These deficiencies were viewed as undermining transparency and preventing users from properly understanding their rights and obligations. TikTok was similarly criticised for inadequate and unclear disclosures concerning its personal data practices, which limited

users’ ability to assess how their information was collected, used, and potentially shared with third parties.

4. Sanctions and corrective measures.

As a result of these violations, VNG was fined VND 810 million, while TikTok was fined VND 880 million.

Beyond the imposition of monetary penalties, the regulator required both companies to terminate the identified non-compliant data processing activities and to review and revise their privacy policies, consent frameworks, and internal compliance measures. These corrective orders indicate that regulatory enforcement in Vietnam is not limited to punitive fines but also focuses on compelling substantive changes to business practices.

5. Legal significance and implications for digital service providers.

This enforcement action reinforces the principle that personal data processing must be grounded in a valid legal basis and that consent obtained through coercive or non-transparent mechanisms may be deemed unlawful. The case is particularly significant in light of Vietnam’s evolving personal data protection framework, including the forthcoming Personal Data Protection Law, which introduces heightened compliance obligations and more severe sanctions.

For digital platforms operating in Vietnam, the decision underscores the importance of revisiting consent design, user interface architecture, and contractual documentation to ensure alignment with regulatory expectations and to mitigate legal and enforcement risks.

About VCI Legal:

VCI Legal is an award-winning business law firm in Vietnam with a wide range of legal and corporate services, among other things, corporate, banking & finance, tax, labor & HR, real estate and dispute resolution with special focus on international investment disputes, We also offer our specialized type of service called “In-House Counsel Service” with the aim of assisting our clients in dealing with all types of internal and external issues arising from their day-to-day operations and business activities. With our offices in both Hanoi and Ho Chi Minh City, we have a tremendous depth of experience in providing well-reasoned and comprehensive legal advice to not only multinationals and Fortune 500 companies, but also small and medium enterprises.

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For many years, VCI Legal has been ranked among the top law firms in Vietnam for corporate, finance, insurance, taxation, employment, intellectual property and investment. With a “Can Do Attitude” combined with a “Know How” capacity, our firm is big enough to provide comprehensive legal support for any in-house legal matters, yet small enough to care about each of our clients. We undertake each engagement with the mindset of a long-term relationship, with the will to give whatever it takes to understand and fulfill your needs.

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