DFNN Privacy Statement

PRIVACY STATEMENT

DFNN, Inc. (“DFNN”, “We” or “The Company”) values an individual’s right to privacy. As such, we ensure that all personal data collected from our customers, vendors, partners, employees, agents and other stakeholders and processed by the organization, our subsidiaries and affiliates are protected at all times in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (Data Privacy Act), its corresponding Implementing Rules and Procedures (IRR), and the existing Memorandum Circulars and Advisories issued by the National Privacy Commission (NPC). Likewise, we make it a point to inform individuals from whom we collect such data of our personal data processing activities and to respect and enforce their rights as data subjects.

This Privacy Policy was created to inform you of the personal data that we collect from you, how we use it, and with whom we share said data.  This Privacy Policy also describes the security measures we undertake to protect your personal data and how you can communicate with us regarding our privacy practices.

This Privacy Policy shall govern your use and access of the Website and of the services therein.  The term “Website” pertains to the website operated and/or owned by DFNN including the mobile versions and mobile applications made available by us, if any. By continuing to access or use our Website or any of the services therein, you agree to be bound by this Privacy Policy.

 

PERSONAL DATA WE COLLECT AND PROCESS

The personal data that we collect are only those necessary and relevant to our dealings with you. Said data will be kept for as long as they are pertinent for the purpose for which they were collected and/or as we are required under the law. We shall immediately destroy or dispose in a secure manner any personal data, the retention of which is no longer allowed under the law.

We collect and process the following types of personal data, among others:

1. Contact Information and employment and/or business affiliation of our customers and individuals representing or affiliated with our vendors, partners, investors and other business contacts;
2. Personal details, credit history, government issued identification, bank account and credit card information of our customers;
3. Shareholder information found in publicly available Securities and Exchange Commission (“SEC”) documents;
4. Contact information, employment history, educational background, biometric information, organizational affiliation, filial relations, gender, date of birth, religion, ethnicity, civil status citizenship, physical medical history, past criminal and/or administrative records, government issued identifying information (such as Pag-IBIG, SSS, TIN, PhilHealth, Professional IDs, Passport, and Birth Certificates), payroll information, company identification of our prospective job applicants, current employees, agents and stakeholders.
5. Information about visitors to our website and social media profiles as well as individuals who use our digital platforms and/or mobile applications. Such information may include, among others, social media profiles, browsing activities, IP Addresses, services procured, and links visited.

The personal data that we collect are those you have voluntarily submitted to us or those data found in publicly available documents. If you provide personal data of any third party to us, we assume that you have obtained the required consent from the relevant third party to share and transfer his/her personal data and to allow us, our agents and third party service providers to process said data in accordance with this Privacy Policy. If you choose to withdraw the consent for the collection, use and processing of personal data, we may not be able to provide you with our services.

 

STORAGE, PROCESSING AND RETENTION

We store and process your personal data in our facilities located in the Philippines. We shall comply with the applicable laws and regulations should we transfer the storage and/or processing thereof outside the country. Only our authorized personnel are granted access to personal data we collect. Personal data collected via the Internet or other electronic methods is stored in a secure IT infrastructure, while physical records of personal data are stored in locked filing cabinets.

We reserve the right to retain and keep your personal data until necessary for business, tax, or legal purposes.

 

PROTECTION OF PERSONAL DATA

We have in place reasonable and appropriate organizational, technical and physical security measures designed to protect the confidentiality, integrity and availability of personal data you provide and we collect.

 

RIGHTS AND RESPONSIBILITY OF DATA SUBJECTS

The personal data you submit to us must be accurate and updated. You are responsible for the accuracy and correctness of any personal data you provide to DFNN, as well as for the consequences of disclosing your personal data to DFNN and failure to provide the accurate, correct and updated personal data.

DFNN fully recognizes that under the Data Privacy Act, our customers, employees, vendors, partners, investors, shareholders and other business contacts and employees, as data subjects, are accorded the following rights:

• Right to be informed

They have the right to demand and be informed of the details about the type of personal data, the purpose of processing, and how they are being processed by DFNN, including its sources, recipients, methods, disclosures to third parties and their identities, automated processes, manner of storage, period of retention, manner of disposal and any changes to such processing activities before the same is undertaken.

• Right to access

They have the right to have reasonable access to their personal data, sensitive or otherwise, upon demand. They have the right to review and amend their personal data processed by DFNN in case there are errors.

• Right to dispute

They have the right to dispute inaccuracy or error in personal data processed by DFNN.

• Right to object

They have the right to reject further processing of their personal data, including the right to suspend, withdraw, and remove their personal data in possession of DFNN which are falsely collected or unlawfully processed.

You may access or request the correction or update of your personal data by sending an e-mail to dataprivacy@dfnn.com, with your full name and the personal data you wish to access or to be corrected or updated.

Should you wish to obtain a hardcopy or printout of such personal data, any and all costs related thereto shall be for your own account.

 

ACCESSING LINKS TO OTHER SITES

Our Website may provide links to other websites, which may operate independently from us. Linked sites have their own privacy notices or policies.  DFNN is not responsible for websites that are not owned or operated by us, we are not responsible for the linked sites’ content, any use of the sites, or the privacy practices thereof.

If you have accessed our online services through a link from our advertising or marketing partners, the personal data you provide to us through these framed web pages is collected by us, and our use of this personal data is governed by this Privacy Policy.

 

DISCLOSURE AND SHARING OF PERSONAL AND COLLECTED DATA

We do not sell or otherwise disclose or transfer personal data we collect about you, except as described in this Privacy Policy. We may share, transfer or disclose your personal data with:

• Our subsidiaries and affiliates;
• Third party service providers who perform services based on our instructions. These service providers are authorized to use or disclose your personal data only as may be necessary to perform services on our behalf or to comply with legal requirements.
• Other third parties with your consent; and
• Other third parties as allowed and limited by Republic Act No. 10173, its implementing rules and regulations, other data privacy laws, and such issuances from the NPC.

We reserve the right to transfer your personal data, so as not to unnecessarily disrupt our transactions with you, in the event we sell or transfer all or a portion of our business or assets. We will use reasonable efforts to direct the transferee to use and process your personal data in a manner that is consistent with this Privacy Policy.

We may also disclose personal data that is necessary to comply with any applicable law, regulation, legal process or governmental request. In addition, we may disclose any personal data when it is necessary to prevent physical harm or financial loss or in connection with suspected or actual illegal activity.

 

USE OF PERSONAL DATA

We use the personal data collected as is. However, if necessary, we may subject the personal data to additional processing before using the same.  We may use the personal data that we collected or that you provided to:

• Process job applications and comply with requirements of government agencies such as, but not limited to, BIR, Pag-IBIG, Philhealth, SSS, etc.
• Respond to your online inquiries and requests
• Improve our online services by performing data analytics
• Generate statistical information
• Comply with applicable legal requirements, relevant industry standards and our policies

We also may use your personal data in other ways for which we provide specific notice at the time of collection.

 

MINORS

DFNN neither offers products or services to, nor knowingly collects personal data of persons below the age of eighteen (18) year (“Minors”) without any legal basis. Should we learn that we were provided with personal data of Minors without any legal basis, we will delete the same from our database. If you are a Minor, please do not disclose any personal data on this website about yourself.

 

WEB BROWSER COOKIES

The DFNN website may use cookies to enhance your experience. Your web browser places cookies on your device for record-keeping purposes and sometimes to track personal data about your use of our website. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the website may not function properly.

 

DATA PROTECTION OFFICER

To oversee our privacy compliance efforts, DFNN has appointed a Data Protection Officer (“DPO”) to manage and safeguard the handling of our personal data processing activities. Likewise, our subsidiaries have appointed individual Compliance Officers for Privacy (“COP”) to ensure that such efforts are sustained throughout the AC family.

Our DPO and COPs are fully committed to protecting the privacy rights of data subjects affected by DFNN’s personal data processing activities and to ensuring that DFNN as an organization promotes a culture of privacy. Should you have any concerns regarding DFNN’s privacy practices and policies, you may reach the DPO through the following contact information: