Aboitiz Data Innovation (“ADI”, “we”, “us”, or “our”) respects and values your privacy. This privacy statement enumerates the practices regarding your personal data and how we will treat it. It sets out how we collect, use, store, disclose, transfer, and dispose of the personal data that you share with us, as well as your rights. ADI acts as a “personal information controller (PIC) or data controller” and a “personal information processor (PIP) or data intermediary” of personal data. The PIC or data controller of the personal data determines the purposes and means and processing of personal data and the PIP or data intermediary processes the personal data on behalf of the controller. We only process personal data in accordance with this Privacy Statement.

Aboitiz Data Innovation as a Personal Information Controller / Data Controller

Information We May Collect

We may collect the following information:

• Contact Form

When filling out the contact form on our website, we need information about you in order to be able to answer your questions or requests. We will use the information collected through the contact form only for the purpose of dealing with your request. For this purpose, we collect the following information:

• Name;
• E-mail Address; and
• Any additional information you provide to us regarding your question or request
• [Potential] Business Connections

During any interaction with you, we may collect personal data for business and marketing purposes. This may include events (i.e. collection of business cards), our options to contact ADI, or you when serving as a contact point for the collaboration with your company. For this purpose, we collect the following information:

• Company Information (name, address, sector);
• Contact Details (name, address and/or mobile / phone numbers);
• Job Title / Designation; and
• Contract information including billing whenever applicable

We process this information based on our legitimate business interest. 

• Recruitment Purposes

In connection with your application for work with us, we will collect, use, and store the following information:

• Personal data such as name, permanent address, present address, date of birth, gender, citizenship, work-related photograph, signature specimen, e-mail address, mobile number, home number, and other contact details;
• Government-issued ID numbers for purposes of payroll and compliance with statutory requirements such as but not limited to:
  • Philippines: SSS, TIN, GSIS, Passport, National ID, Driver’s License
  • Malaysia: Malaysian NRIC, Passport
  • Singapore: NRIC, Passport
  • India: Aadhaar Card, Voter’s ID, PAN Card, Passport
  • EU and EEA: National Identity Card
• Health information from reports in pre-employment medical examination;
• Immigration, right-to-work and residence status whenever applicable;
• Job-related, compensation, and benefits-related information;
• Educational and training information; and
• Any information you have provide to us during an interview and as part of the recruitment process

Personal Data Use

We may process the personal data with the following purposes:

• Customer Supplied Data
  • To provide you with information and services that you request;
  • To provide you with special offers, promotions, surveys, and other information about services we feel may interest you, where you consent to receiving such information;
  • To notify you about changes to this privacy statement and other terms you have agreed to; and
  • To address your queries, complaints, or concerns

• Candidate Supplied Data
  • Assess your skills, qualifications, and suitability for specific vacancy;
  • Check that you are legally entitled to work in the country where the relevant position is available;
  • Subject to your specific consent, assess your skills, qualifications, and suitability for future opportunities;
  • Communicate with you about the recruitment process;
  • Keep records related to our hiring processes; and
  • Comply with legal and regulatory requirements

Data Sharing and Disclosures

We may disclose and share your personal data for legitimate purposes in the following circumstances:

• Any government entity, subdivision, agency, or instrumentality pursuant to statutory requirements;
• Third parties that contracted by us to perform and/or provide services;
• Third parties that perform services in our behalf in relation to health maintenance organization and employee engagements;
• In the event we sell or buy any business or assets, in which we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about or customers will be one of the transferred assets; and
• We may also share your data with Aboitiz & Company, Inc. and its subsidiaries and affiliates, Aboitiz Equity Ventures, and each of their respective subsidiaries and affiliates, and ADI’s subsidiaries and affiliates for the purposes as set out in the Privacy Statement in force, provided by you to us from time to time or for compliance to any law, regulations, government requirement, treaty, agreement, policy or as required by or for the purpose of any court legal process, examination, inquiry, audit, or investigation of any authority. This applies notwithstanding any non-disclosure agreement.

Data Security

We have implemented technical and organizational measures that are appropriate to the obtained personal data. These safeguards are designed to secure your personal data from loss and unauthorized access, copying, use, or modification. We require our service providers to protect your personal data by contractual means.

International Transfer

We may transfer your personal data to parties that are based outside the Philippines and Singapore. In such cases, we ensure that your personal data is processed in a country that has a similar degree of data protection.

Data Retention

     We retain your personal data for as long as necessary for the fulfillment of the purposes we collected it for or in accordance with local laws and regulations whichever is longer. In some circumstances we may anonymize your personal data which means it can no longer be associated with you for research or statistical purposes in which case we may use this information without further notice to you. In cases where local law requires it, we retain your personal data for the following period:

• For financial data and documents which indicate taxable transactions, data shall be preserved for ten (10) years pursuant to Bureau of Internal Revenue (BIR) regulation;
• For recruitment and employee data, personal data shall be retained within five (5) years. 

What Are Your Rights

     Under the Philippine Data Privacy Act and Personal Data Protection Act of Singapore, you have the following rights:

Rights under the Law	Philippines DPA	Singapore PDPA
Right to be informed – right to know what data has been collected and how data is being processed.
Right to access – upon written request, you may demand reasonable access to your personal data, which may include the contents of your processed personal data, the manner of processing, sources where they were obtained, recipients and reason of disclosure.
Right to dispute – you may dispute inaccuracy or error in your personal data in our systems through our Data Protection Officer.
Right to correct / rectification – you may require us to correct / rectify any information and/or personal data relating to you which is inaccurate
Right to object – you may withdraw, suspend, and remove any given consent in respect of the collection, use, or disclosure of your personal data
Right to data erasure / right to be forgotten – subject to applicable laws and reasonable grounds, you have the right to suspend, withdraw or order blocking, removal, or destruction of your personal data from us.
Right to data portability – you have the right to obtain from us your personal data in an electronic or structured format that is commonly used and allows for further use.
Right to damages – you may claim compensation if you suffered due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data.
Right to file a complaint – you can file your complaint or any concerns with our Data Protection Officer and/or with Philippine National Privacy Commission through www.privacy.gov.ph.

In the event wherein customers and/or candidates reside outside the Philippines or Singapore, domestic data protection law shall apply with respect to their rights.  

Aboitiz Data Innovation as a Personal Information Processor or Data Intermediary for its Customers

ADI’s customers determine how and why personal data submitted to us is used, either by or at the directions of such customers. With respect to such personal data, (1) ADI is a “personal information processor” under the Philippine Data Privacy Act (“DPA”) or “data intermediary” under the Singapore’s Personal Data Protection Act (“PDPA”) and (2) ADI’s customers are the personal information controllers or data controllers under DPA and PDPA respectively.

Personal Data Processed 

We act as PIP or data intermediary with respect to any personal data comprised in the customer data. By “customer data” we mean the content or information which individuals and/or organizations authorized by a customer to us.

Use of Your Personal Data

We use personal data to provide our services to our customers pursuant to the applicable data processing terms with our customers.

Data Sharing and Disclosures

We may disclose your personal data in the following circumstances: 

• Contracted providers to carry out services such as but not limited to:
  • Information Technology
  • System Administration and Hosting
  • Customer Support / Service
• When permitted or requested by applicable customers; and
• When required by laws and regulations

Data Security

We take reasonable and appropriate measures to protect your personal data from loss, misuse, and unauthorized access as specified in the data processing terms with the applicable PIC or data controller.

Data Retention

We retain your personal data depending on the data processing terms with our customers, purposes of its collection and processing, and applicable laws and regulations.

Contact Our Data Protection Officer

For inquiries and concerns, you may address them to ADI’s Data Protection Officer at:

• Singapore Head Office: 10 Anson Road #30-01 International Plaza Singapore 079902
• Philippine Head Office: NAC Tower, 32^nd Street, Bonifacio Global City, Taguig City
• E-mail Address: adi.dpo@aboitiz.com

Changes / Amendments / Updates

ADI reserves the right to update or modify this Privacy Statement at any time without prior notice. Any updates will be posted on the ADI’s website.