There is no partial consent clause, only "All consent
In recent days, when accessing the Zalo application, many users suddenly received the notification of Service Terms Update. Notably, the content in these agreements immediately sparked a wave of controversy.
Article 5 of the Zalo User Agreement stipulates: Users agree and agree that VNG (application publisher) has the right to apply technical measures for the purpose of collecting and processing data related to the user's account.
Personal data information (DLCN) includes: Phone number, Full name, age, gender, family relationship, ID card/CCCD/Passport information, personal photos, email.
Also in Article 5, VNG stated: "Receiving and sharing, transferring Account information with Companies under VNG including subsidiaries, member companies, and affiliated companies".
Article 8 "Rights of Data Subjects" stipulates that users have the right to withdraw consent, restriction and objection to handling DLCN (previously agreed) but adds the content "VNG Group Joint Stock Company has the right to refuse to fulfill all user requests if the request does not meet the valid conditions" that this unit sets out.
The Agreement also has Article 14 on "Rejection of Responsibility for Assurance" stating that: "VNG does not provide any assurances including but not limiting assurances on the stability of the Service, information security and safety, or the authenticity of information that Users receive during the use of the Service".
Right below is the content: "In all cases, Users ensure that Users will be exempted from VNG from all liability related to any loss, damage, or expense for any action reason caused by Users' use, or inability to use the Service".
Not only that, what causes great frustration is that if users do not agree with the terms of the agreement issued by Zalo, they will not be able to continue using the service.
A part of users said they did not accept the new usage terms, so they chose to refuse. However, immediately after that, the system immediately notified them that they could not continue using the service and the account would be permanently locked after 45 days. The move made many people feel put in a position of "acceptance or abandonment".
Zalo's agreement is also considered imposing when it only allows "Agreeing with all" but does not agree with part of the content.
This is considered inconsistent with the provisions of Decree 13/2023/ND-CP on DLCN Protection. In Clause 7, Article 11 "Consent of data subjects", this Decree stipulates "Data subjects may partially agree or with accompanying conditions".
Continuously in recent days, many users have expressed outrage at Zalo's new terms update. "Oppose Zalo's excessive pressure, so I will soon delete the app and start switching to another network" - account T.T.L wrote on his personal page on the evening of December 27th.
Question marks about the requirement to be identified by Citizen Identification Card
In addition to the above requirements, to identify accounts, Zalo requires users to take photos of personal papers. Valid papers include: Citizen Identification Card, Identity Card, passport. Zalo said that identification is prioritized when users encounter account-related problems.
Zalo's activity requiring personal papers for identification raises many questions. Because with the nature of a social network platform, current regulations only require users to authenticate with the owner's mobile phone number.
According to Decree No. 147/2024/ND-CP on management, provision, and use of Internet services and information on the network, people are only required to verify social network accounts with their home mobile phone number in Vietnam.
If you are in one of the following 2 cases, you are required to authenticate a social network account using a Citizen Identification Card (i.e., personal identification number): 1. Social network users do not have a phone number in Vietnam. 2. Social network users use the livestream feature for commercial purposes.
In an exchange with Lao Dong Newspaper reporters, lawyer Nguyen Thi Hong - Hoang Thanh Law Firm stated her opinion that Zalo needs to further clarify the application of agreements on DLCN collection, especially in the context that the Law on DLCN Protection is about to take effect from January 1, 2026.
In which, Article 9 of the Law stipulates: The consent of the DLCN subject must ensure the principle of expressing consent for each purpose; It is not allowed to be accompanied by the mandatory condition of consent to other purposes with the content of the agreement;...
In addition, Article 29 on DLCN Protection for social networking platforms and online media services, the Law stipulates "It is not allowed to request the provision of images or videos containing full or part of personal papers as an account authentication factor".
The terms update received great attention, causing much controversy because Zalo has a large number of users in the market, which means a very large amount of data stored and processed. The platform was launched by VNG Group Joint Stock Company in 2012. According to self-published statistics, by September 2025, Zalo has 79 million regular users per month and about 2 billion messages sent every day.
