Privacy Policy

I. INTRODUCTION
 
NETRUST PHILIPPINES CORPORATION (“we” or “us” or “our” or “Netrust”) respects the privacy of our customers (“user” or “you”). Our privacy policy (“Policy”) which was prepared in accordance with the Data Privacy Act 2012(R.A. No 10173), summarizes what personal information we may collect, how we may use this information, and other important topics relating to your privacy and data protection.

This Policy applies to all Internet sites and mobile applications operated by or on behalf of Netrust Philippines Corporation. It also applies to personal information we may otherwise collect: (i) through our products and services; (ii) when you interact with us by means other than our Internet Site or App, for example, in person, by telephone, or at a trade show or training; and (iii) from our customers, distributors, suppliers, vendors, and other business partners (collectively “Business Partners”).

Netrust reserves the right to make changes to this Policy at any time without prior notice. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site.

 
II. COLLECTION OF INFORMATION
Netrust may collect information about our customers in a variety of ways. The information we may collect includes:

 
• Information You Provide
Netrust collects personal information you provide us, which may include:
 
(i) contact information, such as your name, company name, job title, address, e-mail address, and phone number;
 
(ii) additional information about you to help us get to know you better, such as your gender, age, date of birth, nationality, professional associations and registration numbers, information about how you use our products, and demographic information;
 
(iii) comments, questions, requests and orders you may make;
 
(iv) financial information needed to process payments if you make purchases, such as credit card or account information or tax identification number;
 
(v) log-in information, including, if applicable, social media account information for login purposes; and
 
(vi) information about your preferences, such as your preferred methods of communication and product types in which you are interested.
 
 
• Information Automatically Gathered from Your Device
 
Device and browser information
We may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. We collect this information automatically from your device and web browser through cookies and similar technologies.
 
Information about how you interact with us
We may collect technical data about your usage of our Internet Sites and Apps and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, Netrust promotional emails opened, and dates and times of interactions. We collect this information using cookies and similar technologies.
 
Location information
We may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code. Our apps will NOT access precise-real time location information from your device unless you grant permission to do so.
 
 
• Third party social network information
Any information that you share publicly on a third party social network or information that is part of your profile on a third party social network (such as Facebook) and that you allow the third party social network to share with Us. Examples include your basic account information (e.g. name, email address, gender, birthday, current city, profile picture, user ID, list of friends, etc.) and any other additional information or activities that you permit the third party social network to share.
 
• Data Analytics and Advertising
We use third-party analytics services to better understand how users engage with our Internet Sites and Apps, including services provided by Google.
 
We allow selected third parties, including these analytics and advertising services, to place cookies on our Internet Sites. These third parties may collect information about your online activities over time and across third-party websites.
 
 
III. USE OF YOUR INFORMATION
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you to:
 
• Develop and manage our relationships with you
We use your personal information for providing our services to you, including responding to your inquiries, feedbacks and requests. We also use it to process and fulfill your orders, inform you about the status of your orders, and conduct identity verification and other fraud detection activities.
 
• Communicate with you or your company
We use your personal information to provide you with information about our goods or services via marketing communications, campaigns or promotions. This can be done through various means such as email, ads, SMS, phone calls and postal mailings to the extent permitted by applicable laws.
 
• Provide and improve our Internet Sites, Apps, products, and services.
We use your personal information to improve our services by:
 
(i) customizing them to your preferences or interests, or making them easier to use;
(ii) maintaining the security of and otherwise protecting them; and
(iii) developing new Internet sites, Apps, products and services that addresses your needs
 
• Address legal issues.
We use your personal information to:
 
(i) establish, exercise, or defend legal claims;
(ii) comply with laws, regulations, court orders, or other legal process;
(iii) detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of our Internet Sites, Apps, products or services; and
(iv) protect our rights or property, or yours or others’ health, safety, welfare, rights, or property.
 
 
IV. PROCESSING OF SENSITIVE INFORMATION
 
a. Definition of sensitive personal information
Under Philippine law, sensitive personal information refers to personal information:
 
(1) About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;
 
(2) About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;
 
(3) Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and
 
(4) Specifically established by an executive order or an act of Congress to be kept classified.
 
b. Processing of sensitive personal information
We will only process sensitive personal information upon the express consent of the data subject and only for purposes it was provided, or in accordance with law.
 
In processing sensitive personal information, Netrust Philippines Corporation will inform data subjects of the sensitive personal information that is necessary to fulfill the core functionality of the product or service, and the consequences of refusal to the processing, for the purpose of allowing the data subjects to decide whether or not to give consent.
 
 
V. DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
 

By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.
 
Marketing Communications
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
 
Sale or Bankruptcy
If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.
 
 
VI. SECURITY OF YOUR DATA
Netrust maintains reasonable safeguards to protect the confidentiality, security and integrity of your personal information. Although we use security measures to help protect your personal information against unauthorized disclosure, misuse, or alteration, as is the case with all computer networks linked to the Internet, we cannot fully guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control.
 
 
VII. CONSENT 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 us 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, we 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.
 
 
VIII. QUESTIONS ABOUT THIS POLICY
If you have any questions about this Policy or a Specific Privacy Statement or our use of your personal information, you may write to us using the following contact details:

 
Email: [email protected]
 
NETRUST PHILIPPINES CORPORATION
Attention: Data Privacy Officer
Unit 4G1 OPL Building 100 Carlos Palanca Street Legaspi
Village Makati City Philippines 1229