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DATA PRIVACY STATEMENT AND PRIVACY POLICY

CONSENT ON COLLECTION, PROCESSING, PROFILING AND SHARING, AND RETENTION OF DATA AND INFORMATION

  1. I, the Data Subject, agree that by accessing, using, and/or downloading the Tubo.ph Site and App, and continuing to use it and its services means that I accept and agree to be bound the terms stipulated herein, including the Data Privacy Statement.

  2. I hereby agree that all Personal Information and Sensitive Personal Information (as defined under the Data Privacy Act of 2012 and its implementing rules and regulations), customer data and transaction information or records (collectively, the "Information" or “Data”) may be processed, profiled or shared to, by and between Ventaja International Corp., and any of its affiliates and subsidiaries (collectively “Tubo.ph”), its merchants, clients, agents or any government authority as mandated by law.

    1. Personal Information refers to any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual;

    2. Sensitive Personal Information is personal information as defined in the Data Privacy Act of 2012. This information includes but not limited to: marital status, cardholder data (CVV/CVC, Expiry Date), government issued numbers peculiar to an individual (e.g., SSS, GSIS, Pag-IBIG, etc.)  information on identification cards issued by private companies that are duly registered with the Securities and Exchange Commission, and student IDs for those who are not yet of voting age (below 18 years old).

  1. The Data Subject hereby consents to the disclosure, and authorizes Tubo.ph, its third party Affiliates, suppliers, vendors, contractors, and/or its third-party partners to use the Information for the purpose of conducting its operations, and other activities including but not limited to, fraud and risk management, sales and marketing activities, communications relating to their products and/or services, product and system development and innovation, customer experience management and improvement, and market research, to collect and process any and all information related thereto from whatever relevant source.

 

The Data Subject likewise hereby agrees to and authorizes, the disclosure of, and release by, Tubo.ph of his information to third-party partners it contracted or engaged for the fulfillment of its obligations in connection with the Services the Data Subject availed of through the Tubo.ph Site and/or App.

For the avoidance of doubt, the Data Subject hereby acknowledges and agrees that the officers, employees, agents, and other personnel of Tubo.ph may share with each other any and all information relating to the User for any legitimate business purpose including, but not limited to, fraud and risk management, sales and marketing activities, communications relating to their products and/or services, product and system development and innovation, customer experience management and improvement, your products or services availed from a third party, and market research.

The foregoing consents and authorizations shall continue for the duration of, and shall survive the termination of, this Data Privacy Statement and Privacy Policy, or any other transactions, dealings, arrangements, and accounts which you may have with, or avail from, Tubo.ph.

  1. The Data Subject hereby consents to the storage of the Information for any of the legitimate business purposes, including, but not limited to, those mentioned Section 4 hereof.

  2. The Data Subject consents and authorizes Tubo.ph to collect, store, process, disclose, exchange, and release the information you provided to its associates, affiliates, subsidiaries, officers, employees, agents, lawyers, consultants and respective pre-paid/debit/credit bureaus or any such persons as it deems necessary, or as required by applicable laws, rules, or regulations, including but not limited for the following purposes:

      1. facilitating transactions;

      2. availing of third-party products and services;

      3. providing the Data Subject with Tubo.ph Services, such as customer service support;

      4. enhancing the Data Subject’s customer experience and improve, develop, and determine user-tailored products or services;

      5. communicating relevant products and/or advisories to the Data Subject;

      6. abide by any safety, security, public service, or legal requirements and processes; and

      7. processing information for statistical, analytical, and research purposes;

      8. identifying and preventing errors and inefficiencies due to misuse of the Tubo.ph Site and App;

      9. use of biometrics data saved in the Data Subject’s device for the sole purpose of securing his log-in details; and

      10. registering the Data Subject in promotional events.

 

  1. The data shall be stored in Tubo.ph’s system and will not be used for any other purposes other than those specified in the Data Privacy Statement and Privacy Policy.

 

TABLE OF CONTENTS

  1. General

  2. Description of the Information to be entered into the System

  3. Scope and Method of Personal Data Processing, Profiling, Sharing, Retention, and Destruction

  4. Purpose of Information Collection, Processing, Profiling, Sharing, and Storage

  5. Classes and Recipients of the Information

  6. Rights of a Data Subject

  7. Security Measures and Retention of Data

  8. Policy on Minors

  9. Acknowledgement and Consent

  10. Governing Law

  11. Contact Us

 

  1. General

    1. The Data Subject agrees that the use or continued use and availment of the Tubo.ph Site’s and/or App’s features, products and services shall be deemed as the Data Subject’s acceptance and agreement to be bound by the provisions of this Data Privacy Statement and Privacy Policy (the “Policies”). Tubo.ph shall keep the information and files received from the Data Subject or from third parties in the strictest confidence. By providing information to Tubo.ph for the purpose of using the Tubo.ph Site and/or App and availing of its Services, the Data Subject expressly consents to the processing of his supplied User data, as may be applicable for his pertinent transaction using the Tubo.ph Site and/or App. The Data Subject’s data may either be Personal Information or non-personal information, or Sensitive Personal Information.

    2. From time to time, it is necessary for a Data Subject to allow Tubo.ph to undertake collection, processing, profiling, retention, and sharing of Personal Data (as described in Section 2.1.1 hereof), customer, transaction or account data and information in connection with the regular conduct of its business or that of its merchants / clients (collectively, the “Services”).

    3. Failure to supply the Information to Tubo.ph, and allow Tubo.ph to utilize this Information may result in Tubo.ph being unable to provide or maintain the Services to the Data Subject.

    4. The Data Subject hereby agrees that Tubo.ph may amend, revise, and update these Policies and the Tubo.ph’s Terms and Conditions from time to time and that upon notification of such amended Data Privacy Statement and Privacy Policy, the contents thereof shall similarly amend, vary and supplement such Terms and Conditions and agreements and/or arrangements aforesaid with effect from the date specified in such amended Data Privacy Statement and Privacy Policy, and without prejudice to the foregoing, the Data Subject’s use or continued use of any of Tubo.ph’s Services after such change shall also be deemed as his/her acceptance and agreement to the same.

 

  1. Description of the Information to be entered into the System

    1. From time to time, Tubo.ph may collect directly from the Data Subject, or from the Data Subject’s usage and buying behavior within the Tubo.ph Site and/or App, or from third-party sources like social media networks, and enter the data into any of its systems for processing, profiling, storage, and sharing:

      1. 2.1.1.Personal Data about the Data Subject, include, but are not limited to, his full name, age and date of birth, gender, address, Social Security numbers, Pag IBIG numbers, Philhealth numbers, phone number, e-mail address, debit/credit card numbers, bank account information, background on family members and beneficiaries, which may include names, demographic data, contact details, and transaction activity, data and information generated in the ordinary course of Data Subject’s use of the Tubo.ph Site and/or App including browsing and purchasing behavior, participating in promos, contests, surveys and other information and records generated from these activities, and any other Personal Data which the Data Subject has provided to Tubo.ph through any other means;

      2. 2.1.2.Employer-provided information such as employment status, job title, benefits information, and other contact details. This Employment Information is encrypted and stored on secured servers and may only be accessed by the person/s designated by your employer to have administrative access as an Account Administrator;

      3. 2.1.3.Location Data. Tubo.ph may collect location data such as information about your device's location, which can be either precise or imprecise. How much information Tubo.ph collects depends on the type and settings of the device used to access the Services. For example, Tubo.ph may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You may withdraw your permission for Tubo.ph to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services; and

      4. 2.1.4.Information from cookies, or other technologies deployed for analysis of visits to, usage and transactions in websites, mobile applications, SMS or the use of any information technology application of and by Tubo.ph, social media networks, data aggregators and data integrators and other available data sources and the use of the internet.

    2. Tubo.ph may collect certain information by automated or passive means using a variety of technologies, which technologies may be downloaded to your device and may set or modify settings on your device. The information that Tubo.ph collects may include, but is not limited to the following:

      1. 2.2.1.Internet Protocol (IP) address

      2. 2.2.2.Computer/mobile device operating system

      3. 2.2.3.Browser type

      4. 2.2.4.Type of mobile device and the characteristics of the mobile device

      5. 2.2.5.Unique device identifier (UDID) or Mobile Equipment Identifier (MEID) for your mobile device

      6. 2.2.6.Address of a referring web application, if any

      7. 2.2.7.Pages you visit on the Tubo.ph’s Site and/or App and the times of visit.

    3. The Data Subject warrants and ensures that all Personal Data submitted to Tubo.ph is complete, accurate, true, and correct. The Data Subject shall indemnify and hold Tubo.ph free and harmless from and against all losses, damages, claims, suits, third party claims and legal proceedings, direct or indirect, arising from or in connection thereto. In some circumstances that the Data Subject may have provided Personal Data relating to other individuals (such as spouse or family members), the Data Subject represents and warrants that he/she is authorized to provide their Personal Data to Tubo.ph and the Data Subject obtained their consent for their Personal Data to be processed and used in the manner as set forth in these Policies.

 

  1. Scope and Method of Personal Data Processing, Profiling, Sharing, Retention, and Destruction

    1. The scope and method of Personal Data processing by Tubo.ph cover the following: "Processing" refers to any operation or any set of operations performed upon Personal Data including, but not limited to, the collection, recording, organization, storing, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure, or destruction of data, and outsourcing of these activities. Processing may be performed through automated means, or manual processing, if the Personal Data are contained or are intended to be contained in a system.

    2. "Profiling" refers to any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects containing that natural person's economic situation, health, personal preferences, interests, behavior, location or movements.

    3. "Data sharing" or "sharing" is the disclosure or transfer to a third party of Personal Data or Information by Tubo.ph or its data processors or recipients of the data for the purpose of processing.

    4. Retention Period:  Tubo.ph may retain and use your Information for up to three (3) months after the termination of your agreement with Tubo.ph or for as long as reasonably necessary for which it was collected, or to comply with the Tubo.ph’s legal obligations, resolve disputes, and enforce its agreements.

    5. Destruction: The Data pertaining to the Data Subject will be destroyed in irretrievable and unusable form in adherence with Tubo.ph’s physical and/or technical information security measures when retention is no longer required with respect to existing laws, rules, or regulation.

 

  1. Purpose of Information Collection, Processing, Profiling, Sharing, and Storage

    1. Collection and Processing of Personal Data, without limiting the generality of the purpose. shall be for the purposes of:

      1. 4.1.1.Facilitating account creation and authentication and otherwise manage user accounts. Tubo.ph may process your information so you can create and log in to your account, as well as keep your account in working order;

      2. 4.1.2.Availing of third-party products and services;

      3. 4.1.3.Facilitating the Data Subject’s transaction needs and availment of Tubo.ph products and services, among others;

      4. 4.1.4.Enhancing the Data Subject’s customer experience and improve, develop and determine tailored products to meet his preferences and needs;

      5. 4.1.5.Communicating relevant products and/or advisories;

      6. 4.1.6.Sending relevant ads on any of Tubo.ph’s services, and measure the effectiveness and reach of ads services; and

      7. 4.1.7.Abiding by any safety, security, public service or legal requirements and processes, as may be necessary;

    2. The consent of the Data Subject shall be obtained when required by Tubo.ph’s Privacy Policy, the law, and prior to usage or processing of Data for any other purpose.

    3. The Data Subject agrees that the Information may be processed, profiled or shared by Tubo.ph or any person who has legitimately obtained such data from Tubo.ph for any of the following purposes (collectively "Permitted Purposes"):

      1. 4.3.1.To verify the identity the Data Subject as required by law.

      2. 4.3.2.To operate and control the Tubo.ph Site and App, the software and hardware required for such an operation, and the platform which connects various merchants, institutions and companies to Tubo.ph.

      3. 4.3.3.To manage Tubo.ph’s relationship with the Data Subject, which may include providing information about the Data Subject Tubo.ph’s employees or third party providers;

      4. 4.3.4.Other purposes as specified in these Policies and Tubo.ph app’s Terms of Use.

    4. Tubo.ph uses the Data to the extent necessary to comply with the requirements of the laws and legal processes, including orders of governmental agencies, courts, and tribunals; to comply with a legal obligation; or to prevent imminent harm to public security, safety, or order.

    5. The processing of Personal Data will depend on the circumstances. As such, other purposes for the processing of your Personal Data may not appear above. However, Tubo.ph will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the applicable laws.

 

  1. Classes and Recipients of the Information

    1. In addition, the Data Subject agrees that the Information may be processed, profiled, and shared to the following entities inside or outside the Philippines (each, a "Data Recipient"), in accordance with any purpose described in the Permitted Purposes:

      1. 5.1.1.Any person, agent, broker, adviser, contractor or third party service provider who provides administrative, mailing, telemarketing, direct sales, telecommunications, call centre, business process, knowledge management, human resource, data processing, information technology, computer, information security, or other services to Tubo.ph in connection with the operation of the business of Tubo.ph and the Data Subject;

      2. 5.1.2.Any person or entity which is part of Tubo.ph to the extent necessary to fulfil the relevant Permitted Purpose;

      3. 5.1.3.Any person or entity to whom Tubo.ph is under an obligation or otherwise required to make disclosure pursuant to legal process or under the requirements of any foreign or domestic law, regulation, court order or agreement entered into, binding on or applying to Tubo.ph, or agreement entered into by Tubo.ph and any foreign or domestic Authority or between or among any two or more domestic or foreign Authorities, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any Authority, or Industry Organization with which Tubo.ph is required or expected to comply or participate, or any disclosure pursuant to any contractual or other commitment of Tubo.ph with an Authority, or Industry Organization, all of which may be within or outside Philippines including disclosure to any Authority, whether such legal process, obligation, request, requirement, agreement or guidance may be existing currently or created in the future;

      4. 5.1.4.The respective subcontractor, assignee, vendor, or delegate of each of the above-described person or entity.

    2. Tubo.ph may need to share your Personal Data in the following situations:

      1. 5.2.1.Business Transfers. Tubo.ph may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

      2. 5.2.2.When Google Maps Platform APIs are used. Tubo.ph may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link. Tubo.ph obtains and stores on your device (“cache”) your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.

 

  1. Rights of a Data Subject

    1. Under and in accordance with the terms of the Data Privacy Act, any individual has the right:

      1. 6.1.1.To be informed whether Personal Data is being or has been processed. This includes processing through automated decision-making and profiling;

      2. 6.1.2.To be notified and furnished with information before the entry of his Personal Data into the processing system of the personal information controller, or at the next practical opportunity:

      3. 6.1.3.To require Tubo.ph to correct any Personal Data relating to the Data Subject which is inaccurate or erroneous, unless the request for rectification or correction is vexatious or otherwise unreasonable;

      4. 6.1.4.To object to the processing of the Personal Data in case of changes or amendments to the Personal Data supplied or declared to the Data Subject;

      5. 6.1.5.To access the Personal Data, upon demand;

      6. 6.1.6.To suspend, withdraw or order the blocking, removal, or destruction of the Data Subject's Personal Data from Tubo.ph’s system. It is understood and acknowledged by the Data Subject that where the Data Subject exercises his right set out in this provision, Tubo.ph reserves its right to terminate the Services;

    2. Nothing in these Policies shall limit the rights of Data Subjects under the Data Privacy Act.

    3. If Tubo.ph is relying on your consent to process your Personal Data, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting Tubo.ph by using the contact details provided in the “Contact Us” section below. However, depending on the circumstances and the nature or extent, the withdrawal of consent may result in the Tubo.ph’s inability to provide Services to you. Further, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

    4. You can unsubscribe from Tubo.ph’s marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that Tubo.ph send, or by contacting Tubo.ph using the details provided in the “Contact Us” section below. You will then be removed from the marketing lists. However, Tubo.ph may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

 

  1. Security Measures and Retention of Data

    1. Tubo.ph ensures the presence of reasonable and appropriate physical, technical, and organizational privacy and security measures to protect against any threat to the confidentiality, availability and integrity in the processing of the Data Subject’s Personal Data.

    2. Third parties may unlawfully intercept or access Personal Data transmitted to or contained on Tubo.ph’s Site and/or App or technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse your Personal Data through no fault of Tubo.ph. Tubo.ph will deploy reasonable security arrangements to protect your Personal Data as required by the applicable laws. However, there is no guarantee of absolute security such as those arising from malicious and sophisticated hacking through no fault of Tubo.ph. In case of breach of Personal Data, Tubo.ph shall report the same to the National Privacy Commission in accordance with the breach reporting procedures specified under the Data Privacy Act.

    3. Tubo.ph may retain and use your Information for up to three (3) months after the termination of your agreement with Tubo.ph or for as long as reasonably necessary for which it was collected, or to comply with Tubo.ph’s legal obligations, resolve disputes, and enforce its agreements. If Tubo.ph is required to retain any portion of the Information, Tubo.ph shall use reasonable efforts to limit the use of such Information to what is necessary to accomplish the particular purpose. Tubo.ph will take reasonable steps to delete your Information as quickly as possible upon your request.

    4. When Tubo.ph has no ongoing legitimate business need to process your Personal Data, Tubo.ph will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then Tubo.ph will securely store your personal information and isolate it from any further processing until deletion is possible.

 

  1. Policy on Minors

 

Tubo.ph does not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If Tubo.ph learns that personal information from users less than 18 years of age has been collected, Tubo.ph will deactivate the account and take reasonable measures to promptly delete such data from our records.

 

  1. Acknowledgement and Consent

 

    1. By accessing the Tubo.ph Site and/or App and clicking the “Agree & Continue” button or any other button which expresses your assent to these Policies, you acknowledge that you have read and understood these Policies and agree and consent to the collection, use, storage, retention, transfer, and processing of your Personal Data by Tubo.ph as described in these Policies.

    2. By (1) clicking “Yes” on our Policies or Privacy Notice pop-up or any web form referring to the amended Policies on any of our platforms, (2) submitting your Personal Data to Tubo.ph when signing up for an account, (3) using the Tubo.ph Site and/or App or (4) continuing to use the Tubo.ph Site and/or App after the posting of an amended Privacy Policy or Privacy Notice, you are agreeing to the terms of the amended Policies.

    3. You are encouraged to visit www.tuboph.com/privacy-policy from time to time to ensure that you are well-informed of the latest policies of the Tubo.ph in relation to Personal Data protection.

 

 

 

  1. Governing Law

 

These Policies and your use of Tubo.ph’s Site and/or App shall be governed in all respects by the laws of the Republic of the Philippines.

 

  1. Contact Us

 

For any questions or complaints relating to your Personal Data or about these Policies, you may contact us at info@tubo.ph.

 

 

 

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