Last updated: January 14, 2019
P.A. Alvarez Properties and Development Corporation and its subsidiaries and affiliates (collectively referred as, “P.A. Properties”, “the company”, “we”, “us” or “our”) respect your privacy with regard to personal data. This statement is one way of sustaining your trust in our company, our products and our services. We recognize the need to treat this personal data in an appropriate and lawful manner in line with our commitment to comply with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA). We are dedicated to comply with our obligations in this regard, in respect of all personal data that we handle.
This statement aims to ensure that you are aware of how we collect, process and use your personal data through our websites, information systems and processes. This also aims to ensure that you know how you can exercise your rights related thereto.
When you disclose to us another person’s personal information (i.e. your dependent, spouse, attorney in fact, co-borrowers and partners) you attest that consent has been obtained from that person to disclose and process personal information in accordance with this policy.
3 YOUR PERSONAL INFORMATION
As part of our transactions with you, we may collect your personal data including but not limited to:As part of our transactions with you, we may collect your personal data including but not limited to:
3.1 Your name, gender, civil status, date of birth, address, telephone or mobile numbers, email address, mailing address, proof of identification and any other information relating to you
3.2 Your work related information regarding your company, your ownership and participation
3.3 Your bank account information and credit history when you avail our products and services or when you apply for supplier accreditation
3.4 Your employment history, education background, resume and income information when you apply for a job with us
3.6 Your social media behavior when you tag, mention, or post photographs of any of our projects and our subsidiaries publicly on any social media account (e.g. Facebook, Twitter, Instagram, etc.)
4 MANNER OF COLLECTION
We may collect and store your Personal Information in the following manner:
4.1 When you purchase, avail or join any of our products, services, promos, activities, and events
4.2 When you interact with our sales agents, reservation officers, or customer care representatives through email, phone, chat services or face-to-face meetings
4.3 When you submit information through any form on our digital assets (i.e. websites, apps), or contact us through any of our social media accounts (e.g. Facebook, Twitter, Instagram, etc.)
4.4 When you provide personal information in relation to inquiries, requests, and complaints
4.5 When you respond to surveys, promotions, and other marketing and sales initiatives
4.6 When you submit a job application
4.7 When we receive references from third parties or our business partners (i.e. when you have been referred by them)
4.8 When you submit your personal information to us for any other reason
5 INTENDED PURPOSE
5.1 General Use of Personal Information
The company collects and uses your Personal Information for the following purposes:
5.1.1 To provide you with product and services that you have availed or requested
5.1.2 To communicate relevant services, advisories including responses to your queries, requests and complaints
5.1.3 To provide information about our products and services which may be of interest to you
5.1.4 To comply with the requirements of the law and with our legal obligations
5.1.5 To prevent, detect, investigate and manage security risks and incidents
5.1.6 To manage information for statistical, analytical and research purposes
5.2 General Use of Personal Information
We may use your information in the following manner depending on the nature of your transaction with us:
5.2.1 Processing of Inquiry or Purchase of our Products
220.127.116.11 To conduct proper due diligence checks
18.104.22.168 To record your inquiry and address any follow-up matters
22.214.171.124 To prepare all necessary sales documentation and any other documentation as may be requested
126.96.36.199 To perform all financial processes related to the sale such as the setup of downpayment, amortization or financing and perform other actions necessary in the implementation of our contract
188.8.131.52 To manage all administration of unit turn over activities
184.108.40.206 To communicate all advisories and changes in relation to the sale
220.127.116.11 Any other purpose relating to any of the above
5.2.2 Processing of Merchant or Tenant Application in our Properties for Lease
18.104.22.168 To conduct proper due diligence checks
22.214.171.124 To conduct proper due diligence checks
126.96.36.199 To record and process your application
188.8.131.52 To prepare leased out documentation and any other documents as may be required
184.108.40.206 To perform financial transactions such as the processing of rental payments and perform other actions necessary in the implementation of our contract
220.127.116.11 To communicate any advisories, or changes in terms and condition related to your lease contract
18.104.22.168 Any other purpose relating to any of the above
5.2.3 Supplier and Contractor Accreditation and Relations
22.214.171.124 To conduct proper due diligence checks
126.96.36.199 To evaluate your proposal and to conduct corresponding background checks
188.8.131.52 To assess your feasibility as a vendor and process your accreditation
184.108.40.206 To communicate with you about matters relating to our required products and services
220.127.116.11 To perform other actions necessary in the implementation of our contract
18.104.22.168 Any other purpose relating to any of the above
5.2.4 Processing of Employment Application and Employee Management
22.214.171.124 To process your application including any of the following:
126.96.36.199.1 Conducting a background check
188.8.131.52.2 Conducting aptitude and personality tests and checks
184.108.40.206.3 Conduct of interviews
220.127.116.11.4 Facilitating medical check-ups and clearances
18.104.22.168.5 Collecting information about your suitability for the position
22.214.171.124 To administer benefits and payroll processing
126.96.36.199 To organize training and development
188.8.131.52 To assess your performance
184.108.40.206 To perform other actions necessary in the implementation of your employment contract
220.127.116.11 Any other purpose relating to any of the above
We may disclose your personal information to the following as reasonably necessary depending on the product and service concerned:
Any individual or company with which we share information about you for the below purposes is required to comply with confidentiality standards, undertaken to respect any individual’s right to privacy and to comply with the Data Privacy Act. We also require that they use this information only for our purposes and follow our reasonable directions with respect to this information.
6.1 Our employees and officers
6.2 Professional advisers such as lawyers and auditors
6.3 Insurers and credit providers
6.4 Banks and their respective service providers
6.5 Suppliers or subcontractors, third party service providers, consultants that we have to provide financial, technical, architectural, administrative services such as information technology, payroll, accounting, sales administration, procurement, training and other services
6.6 Any third party businesses offering goods and services or sponsor contest or other marketing and promotional programs;
6.7 Members of our group of companies, subsidiaries and affiliates and our joint venture partners;
6.8 Buyer or prospective buyer of any business or asset that we are contemplating to sell
We may also disclose your personal information to the extent that we are required to do so by applicable law and/or rules and regulations and in connection with any ongoing or prospective legal proceedings.
7 RETENTION AND DISPOSAL
We will retain documents (including electronic documents) containing your personal data:
7.1 to the extent that we are required to do so by law;
7.2 to the extent required by or pursuant to our contract;
7.3 if we believe that the documents may be relevant to any ongoing or prospective legal proceedings.
Thereafter your personal information shall be disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public.
You may instruct us to provide you with any personal information we hold about you. This will be subject to the required presentation of appropriate evidence of your identity.
However, we may withhold personal information that you request to the extent permitted by law
9 UPDATING OF INFORMATION
If the personal information that we hold about you needs to be corrected or updated, the company shall make all reasonable efforts to ensure that these data are current, complete and accurate. You may send your request to access and update your personal data to email@example.com or you may contact our customer care representatives.
As part of our security measures, we will contact you and conduct the necessary verification measures to process your request. Once we have implemented the necessary correction, we shall then notify you that your requests have been processed.
10 WITHDRAWAL OF CONSENT
If you wish to withdraw your consent given for any or all purposes set out in this Policy, you may send your detailed request to firstname.lastname@example.org. Depending on the nature of your consent withdrawal, the company may not be in a position to continue to provide our products and services to you.
11 GENERAL MANAGEMENT AND SECURITY
Data Protection Officers for P.A. Properties and for its subsidiaries and its affiliates have been appointed to manage and safeguard the handling of your Personal Data compliant with the Philippine Data Privacy Act of 2012 or RA 10173 and this Policy. Our Management is committed to ensure that our Privacy Management Program is constantly reviewed, monitored and enhanced. We regard personal data breaches very seriously.
12 SECURITY MEASURES
12.1 Information in Physical Format
Your personal data that are in paper format shall be maintained, stored and locked in filing cabinets under the custody and responsibility of the departments who own the information. Access to these documents shall be limited to concerned departments after obtaining approval from the head of the owner department.
12.2 Information in Digital Format
Nevertheless, we maintain physical, technical and organizational safeguards to protect your personal data against loss, theft, unauthorized access, disclosure, copying, use or modification. We also put in effect safeguards such as:
12.2.1 Use of secured servers behind advance threat protection appliances, firewalls, encryptions and other security tools
12.2.2 Limit on the access to your personal information to those who are qualified and authorized to process them. All such persons, wherever they are located, are required by us to protect the confidentiality and privacy of your personal information in a manner consistent with our privacy policies and practices
12.2.3 Regular security vulnerability and penetration audit of our information system/infrastructure to ensure your personal information is properly protected
13 THIRD PARTY WEBSITES
14 COOKIES AND SIMILAR TECHNOLOGIES
A cookie is a small file which upon your permission, is placed on your computer’s hard drive. This aids in the analysis of the web traffic that you create online.
A cookie in no way gives us access to your computer or any information about you, other than the information about your browsing behaviour. Cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. This helps us develop promotional offers, products, and services that we feel are beneficial to you.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
15 BREACH AND SECURITY INCIDENTS MANAGEMENT
In case of reported personal data breach and security incidents, P.A. Properties will conduct the following measures through its Data Breach Response Team:
15.1 Initial Investigation of the Breach
15.1.1 Identification and conduct of immediate action to stop the source of breach
15.1.2 Determination of the nature, extent, scope, and circumstances surrounding the breach
15.1.3 Determination of the possible personal data involved
15.1.4 Ascertaining the data subjects affected
15.1.5 Documentation of all initial information gathered for further investigation
15.2 Mitigation of the Impact of the Breach
15.2.1 Restoration of the integrity of the system
15.2.2 Change in the encryption keys and passwords if applicable
15.2.3 Isolation and preservation of the compromised data if there is any
15.2.4 Attempts to retrieve the lost or compromised data if there is any
15.2.5 Preparation of back-up mechanism
15.2.6 Securing of all evidence and reports
15.2.7 Coordination and cooperation with law enforcement agencies
15.3 Notification regarding the Breach
If it is determined after investigation that a security breach has occurred, the Data Privacy Officer shall notify the Senior Management and the responsible departments about the case and provide them with advice and guidance.If the breach was determined to have an effect to external parties, these individuals or organizations shall be notified within three (3) business days from the discovery of a confirmed breach. The Data Protection Officer shall provide them with an (a)Incident Report; (b)instructions on how data subjects will get further information; and (c) recommendations on how to minimize risks resulting from breach.
16 UPDATES TO THE POLICY
17 DPO CONTACT INFORMATION
Data Privacy Officer
Tel No.: +63939-915-5348