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DATA PROTECTION NOTICE

This Data Protection Notice ("Notice") sets out the basis which [name of organisation] ("we", "us", or "our") may collect, use, disclose or otherwise process personal data of our customers in accordance with the Data Protection Act ("DPA").

This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

1. As used in this Notice:
   1. "customer" means an individual who (a) has contacted us through any means to find out more about any products, goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
   2. "personal data" means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your name, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
3. Other terms used in this Notice shall have the meanings given to them in the DPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your "authorised representative") after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the DPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
5. We may collect and use your personal data for any or all of the following purposes:
   1. performing obligations in the course of or in connection with our provision of the products, goods and/or services requested by you;
   2. verifying your identity;
   3. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
   4. managing your relationship with us;
   5. sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
   6. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
   7. any other purposes for which you have provided the information;
   8. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Philippines or abroad, for the aforementioned purposes; and
   9. any other incidental business purposes related to or in connection with the above.
6. We may disclose your personal data:
   1. where such disclosure is required for performing obligations in the course of or in connection with our provision of the products, goods or services requested by you; or
   2. to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.
7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

WITHDRAWING YOUR CONSENT

8. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email.
9. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
10. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
11. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

12. If you wish to make
    1. an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or
    2. a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email.
13. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the DPA).

PROTECTION OF PERSONAL DATA

14. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
15. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

16. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing us in writing or via email.

RETENTION OF PERSONAL DATA

17. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
18. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF PHILIPPINES

19. We generally do not transfer your personal data to countries outside of Philippines. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the DPA.

EFFECT OF NOTICE AND CHANGES TO NOTICE

20. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
21. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

ACKNOWLEDGEMENT AND CONSENT

I acknowledge that I have read and understood the [above Data Protection Notice], and consent to the collection, use and disclosure of my personal data by [name of organisation] for the purposes set out in the Notice. Further, I would like to receive information about the goods and services which may be provided by [name of organisation], including (but not limited to) offers, promotions and information about new goods and services, via the following channels, newsletter or email or text message and telephone call.

MYEG PH

Overview

I-PAY MYEG PHILIPPINES INC. (MYEG PH) has developed this Privacy Policy to explain how we may collect, retain, process, share and transfer your Personal Data when you visit our Sites or use our Services. This Privacy Policy applies to your Personal Data when you visit Sites or use Services, and does not apply to online websites or services that we do not own or control, including websites or services of other partners of MYEG PH.

This Privacy Policy is designed in compliance with Republic Act No. 10173 or the Data Privacy Act (2012), Its Implementing Rules and Regulations, and other relevant policies, including issuances of the National Privacy Commission to help you obtain information about our privacy practices and to help you understand your rights and privacy choices when you use our Sites and Services.

We have defined some terms that we use throughout the Privacy Policy. You can find the meaning of a capitalized term in the Definitions section.

Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Policy.

Personal Data That We Collect

The following personal information will be collected when using our Sites or use its accompanying Services:

Registration and use information – Upon registration to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfill the Services you request. Depending on the Services you choose, we may require you to provide us with your name, postal address, telephone number, email address and identification information to establish an Account. We may require you to provide us with additional Personal Data as you use our Services.

Transaction and experience information – When you use our Services or access our Sites, to make purchases from our partner merchants to process payments, we collect information about the transaction, as well as other information associated with the transaction such as amount paid for products or services, merchant information including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geolocation Information.

Participant information – When you use our Services or access our Sites, we collect Personal Data you provide us about the other participants associated with the transaction.

Information that you choose to provide us to obtain additional Services or specific online Services – If you request or participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection, if the use of that information differs from the uses disclosed in this Privacy Policy.

Information about you from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.

Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

Retention Of Data

We retain Personal Data to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.

Processing Of Personal Data

We may Process your information for the following reasons:

• To operate the Sites and provide the Services, including to:
  • Initiate a payment or pay a bill;
  • Authenticate your access to an Account;
  • Communicate with you about your Account, the Sites, the Services, of MYEG PH;
  • Create an account connection between your Account and a third-party account or platform; and
  • Perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes.

• To manage our business needs, such as monitoring, analyzing, and improving the Services and the Sites’ performance and functionality. For example, we analyze User behavior and perform research about the way you use our Services.

• To manage risk and protect the Sites, the Services and you from fraud by verifying your identity, and helping to detect and prevent fraud and abuse of the Sites or Services.

• To market to you by delivering marketing materials about MYEG PH’s products and online Services and the products and services of unaffiliated businesses. We may also Process your Personal Data to tailor certain Services or Site experiences to better match our understanding of your interests.

• To provide personalized Services offered by MYEG PH on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Policy to provide a targeted display, feature or offer to you on third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as advertising or analytics companies to provide these online services.

• To provide you with location-specific options, functionality or offers if you elect to share your Geolocation Information through the Services. We will use this information to enhance the security of the Sites and Services and provide you with location-based Services, such as advertising, search results, and other personalized content.

• To comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations.

• To respond to your requests, for example to contact you about a question you submitted to our customer service team.

Sharing Of Personal Data

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy.

We may share your Personal Data or other information for the following reasons:

With other members of the MYEG PH affiliated companies: We may share your Personal Data with members of the MYEG PH entities to, among other things, provide the Services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of MYEG PH products, Services, and communications.

With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, send you advertisements for our products and Services, or provide customer support.

With other financial institutions that we have partnered with to jointly create and offer a product or service: We may share Personal Data with other financial institutions that we have partnered with to jointly create and offer a product. These financial institutions may only use this information to market and offer MYEG PH-related products, unless you have given consent for other uses.

With the other parties to transactions when you use the Services, such as other Users, merchants, and their service providers: We may share information with the other participants to your transactions, including merchants or their service providers when you use the Services to pay for goods or services. The information includes:

• Personal Data necessary to facilitate the transaction;
• Information to help other participant(s) resolve disputes and detect and prevent fraud; and
• Aggregated data and performance analytics to help merchants better understand Users and to help merchants enhance Users’ experiences.

With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for MYEG PH’s business purposes or as permitted or required by law, including:

• if we need to do so to comply with a law, legal process or regulations;
• law enforcement, regulators, government officials, or other third parties (in Philippines or elsewhere) in relation to a subpoena, court order, or other legal process or requirement under Philippine law or regulation, or the laws and regulations of other jurisdictions that are applicable to MYEG PH or one of its affiliates; when we need to do so to comply with such law or credit card rules; or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss; or to report suspected illegal activity or to investigate violations of a user agreement;
• to protect the vital interests of a person;
• to protect our property, Services and legal rights;
• to facilitate a purchase or sale of all or part of MYEG PH’s business;
• in connection with shipping and related services for purchases made using a Service;
• to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants;
• to banking partners as required by card association rules for inclusion on their list of terminated merchants;
• to credit reporting and collection agencies;
• to companies that we plan to merge with or be acquired by; and
• to support our audit, compliance, and corporate governance functions.

With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account connection with a third-party account or platform.

In addition, MYEG PH may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services. We do not share your Personal Data with third parties for their marketing purposes without your consent.

Working with Other Services and Platforms

Taking advantage of MYEG PH’s diverse payment options is that you can connect your Account with a third-party account or platform. For the purposes of this Privacy Policy, an “account connection” with such a third-party is a connection you authorize or enable between your Account and a non-MYEG PH account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, MYEG PH and the third-party will exchange your Personal Data and other information directly. Examples of account connections include:

• Linking your Account to a social media account or social messaging service;
• Connecting your Account to a third-party data aggregation or financial services company, if you provide such company with your Account log-in credentials; or
• Using your Account to make payments to a merchant or allowing a merchant to charge your Account.

If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your Account to a social media account, we will receive Personal Data from the social media provider via the account connection. If you connect your Account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and transactional information, such as purchases and funds transfers. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Policy.

Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your Personal Data as part of the account connection.

Use of Cookies and Tracking Technologies

When you visit our Sites, use our Services, or visit a third-party website for which we provide online Services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a User and to customize your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services. Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible.

Privacy Choices That Are Available

You have choices when it comes to the privacy practices and communications described in this Privacy Policy. Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of a Site. You may be provided with instructions and prompts within the experiences as you navigate the Services.

• Choices Relating to the Personal Data We Collect
• Personal Data. You may decline to provide Personal Data when it is requested by MYEG PH, but certain Services or all of the Services may be unavailable to you.
• Location and other device-level information. The device you use to access the Sites or Services may collect information about you, including Geolocation Information and User technical usage data that MYEG PH may then collect and use.

• Choices Relating to Our Use of Your Personal Data
  • Personalized Services offered by MYEG PH on third-party websites and services. You may manage your preferences for other MYEG PH Services that are personalized and offered to you on third-party websites from your Account. We may also provide you with instructions and prompts on how to manage your preferences within the Service experience.

• Choices Relating to Account Connections
  • If you authorize an account connection to a third-party account or platform, such as a social media account, you may be able to manage your connection preferences from your Account or the third-party account or platform. Please refer to the privacy notice that governs the third-party platform for more information on the choices you may have.

• Choices Relating to Cookies
  • You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting AboutCookies.org. You may choose to enable these options, but doing so may prevent you from using many of the core features and functions available on a Service or Site.
  • You may have an option regarding the use of cookies and other tracking technologies when you use a Service or visit parts of a Site. For example, you may be asked if you want the Service or Site to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.

• Choices Relating to Your Registration and Account Information
  • If you have an Account, you generally may review and edit Personal Data by logging in and updating the information directly or by contacting us. Contact us if you do not have an Account or if you have questions about your Account information or other Personal Data.

• Choices Relating to Communication
  • Notices, Alerts and Updates from Us:
    • Marketing: We may send you marketing content about our Sites, Services, products, products we jointly offer with financial institutions, as well as the products and services of unaffiliated third parties and members of the MYEG PH corporate group through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt out of these marketing communications by following the instructions in the communications you receive. If you have an Account with us, you may also adjust your communication preferences in your Account settings. For messages sent via push notifications, you may manage your preferences in your device.
    • Informational and Other: We will send communications to you that are required or necessary to send to Users of our Services, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications. However, you may be able to adjust the media and format through which you receive these notices.

Protection Of Personal Data

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized.

Underage Access Restrictions

The Sites and Services are not directed to children under the age of 13. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

Miscellaneous

Changes to This Privacy Policy.

We may revise this Privacy Policy from time to time to reflect changes to our business, the Sites or Services, or applicable laws. The revised Privacy Policy will be effective as of the published effective date.

If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on the “Policy Update” page of our website. We also may notify Users of the change using email or other means.

Transfers of Your Personal Data to Other Jurisdictions

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers store and Process your Personal Data in the Republic of the Philippines and elsewhere in the world. We will protect your information as described in this Privacy Policy if your Personal Data is transferred to other jurisdictions. By using our Sites and Services, you consent to your Personal Data being transferred to other jurisdictions, including jurisdictions that have different data protection rules than your jurisdiction. We do not represent that our Sites and Services are appropriate or available in any particular jurisdiction.

Contact Us

You may contact us if you have general questions about our Privacy Policy and practices or questions about your Account information or Personal Data. (Provide contact support information of MYEG PH)

Definitions

Account means a registered MYEG PH account.

Device Information means data that can be automatically collected from any device used to access the Sites or Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device’s IP address; information about your device’s web browser and the internet connection being used to access the Site or Services; Geolocation Information; information about apps downloaded to your device; and biometric data (e.g., Touch ID/Fingerprint to verify your identity).

Geolocation Information means information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. Some of our Services may ask you for permission to share your current location. Some of the Sites and Services require this information to provide a specific product or online Service. If you do not agree to our collection of the geolocation information, our Sites or Services may not function properly when you try to use them.

MYEG PH means I-PAY MYEG PHILIPPINES INC. and subsidiaries or affiliates. In this Privacy Policy, MYEG PH is sometimes referred to as “we,” “us,” or “our,” depending on the context.

Personal Data means personal information that can be associated with an identified or identifiable person. “Personal Data” can include name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, passport, Social Security number and TIN ID). Personal Data does not include information that does not identify a specific User.

Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.

Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by MYEG PH in connection with an Account.

Sites means the websites, mobile apps, official social media platforms, or other online properties through which MYEG PH offers the Services and which has posted or linked to this Privacy Policy.

Technical Usage Data means information we collect from your phone, computer or other device that you use to access the Sites or Services. Technical Usage Data tells us how you use the Sites and Services, such as what you have searched for and viewed on the Sites and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies.

User means an individual who uses the Services or accesses the Sites and has established a relationship with MYEG PH (for example, by opening an Account and agreeing to the MYEG PH User Agreement) or otherwise uses the Services as a buyer or other type of participant to a transaction.

I agree with the Privacy Policies as set by MYEG Insurance Agency Inc.