VCI Legal – January 3, 2026

Following its recent update to the terms of service, Zalo — one of Vietnam’s leading messaging platforms — has attracted growing legal and public attention, as experts and authorities have raised concerns that certain provisions may be inconsistent with key Vietnamese legislation, including the Law on Protection of Personal Data, the Law on Consumer Protection, and the Competition Law.

1. Allegations of Personal Data Protection Law Violations
Legal analysts have argued that Zalo’s new terms grant the platform extensive rights to collect, use, and share personal data — including sensitive information — without truly informed and voluntary consent from users. Critics contend this contradicts the principles of the Law on Protection of Personal Data, which requires clear, specific, and freely given consent for data processing.

Furthermore, some provisions reportedly allow Zalo to process broad categories of data and claim exemptions from liability if data is leaked due to cyberattacks or system errors, raising concerns about insufficient safeguards and responsibility for personal information security.

2. Consumer Protection Law Concerns
Under the Law on Consumer Protection, contractual terms between businesses and users must not create significant imbalances in rights and obligations. However, Zalo’s updated terms require users to either “agree to all” conditions — including extensive data processing clauses — or risk having their accounts disabled or permanently deleted after a 45-day period. Critics argue this “take-it-or-leave-it” approach effectively coerces users, stripping them of a meaningful choice and potentially constituting unfair contract terms under consumer protection standards. Legal commentary also highlights provisions that broadly exempt Zalo from liability in key scenarios and limit users’ ability to challenge unfair practices, which may further violate consumer rights protections.

3. Competition Law Implications
Zalo’s dominant position in Vietnam’s messaging and social app market — with tens of millions of active users — has triggered scrutiny under the Competition Law. Experts suggest that leveraging this dominant market power to impose stringent data consent conditions may amount to abusive conduct that stifles competition and restricts consumer choice.

Indeed, the Vietnam Competition Authority has reportedly summoned Zalo’s parent company VNG for explanation amid concerns over how the updated terms affect user rights and competitive dynamics.

Public and Regulatory Pushback
The updated terms have sparked a wave of public criticism — including negative user ratings and calls for boycotts — while regulators and legal professionals call for deeper investigation. The controversy has also prompted comparisons to international cases where dominant digital platforms were sanctioned for similar conduct.

What Comes Next?
Regulators, including the Competition Authority and consumer protection agencies, are expected to intensify review and may pursue enforcement actions if the terms are found to violate Vietnamese law. The unfolding situation highlights broader challenges in balancing digital innovation with legal compliance and the protection of user rights in the era of big data.

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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