Privacy Policy
We respect your privacy.
We are committed to protect and respect your personal
data, guided by the relevant provisions of data privacy
laws and regulations.
The following provides an overview of how your privacy is
respected and protected on this website:
What information do we gather?
With your informed consent, we collect the following
personal data in our website:
|
Category of Personal Data
|
Specific Personal Data Collected
|
| 1. Personal Details |
First Name, Last Name. |
| 2. Contact Details |
E-mail Address, Phone Number |
|
3. Usage Data / Cookies* and geolocation data
|
Internet Protocol Address (IP Address), browser
type, browser version, the pages of the website
visited, the time and date of visit, the time spent
on specific pages of the website, unique device
identifiers and other diagnostic data.
|
* Cookies are text files containing small amounts of
information which are downloaded to your computer or
mobile device when you visit a site and allow a site
to recognize your device.
If you are uncomfortable regarding the use of cookies, you
can disable cookies on your computer by changing the
settings in the preferences or options menu of your
browser.
For which purposes and on which legal basis do we use
your personal data?
We use your personal data only where required for specific
purposes. The list of purposes and the corresponding legal
basis for the collection of your personal data are
outlined in the table below:
|
Personal Data Collected
|
Purpose |
Legal Basis |
|
1. Personal Details and Contact Details
|
Facilitating communication with you
|
Justified on the basis of our legitimate interests
for ensuring proper communication and to address
properly your inquiry or concern.
a) Justified on the basis of our legitimate
interests for ensuring that you receive an
excellent user experience, and our networks and
information are secure.
b) Justified on the basis of our legitimate
interests for ensuring that we only show you
content based on the consent you provided.
|
|
2. Usage Data / Cookies and geolocation data
|
Improving the security and functionality of our
website, networks, and information; analyze traffic,
enable social media functionality, and offer you
marketing content and advertisements according to
your interests.
|
What about sensitive personal data?
We do not seek or collect or otherwise process sensitive
personal data through this site. Where it becomes
necessary to process your sensitive personal data for any
reason, we rely on your prior express consent for any
processing which is voluntary (e.g., for marketing
purposes). If we process your sensitive personal data for
other purposes, we rely on the following legal bases: (i)
detection and prevention of crime (including the
prevention of fraud); (ii) establishment, exercise, or
defense of legal claims; and (iii) compliance with
applicable law.
How do we collect your personal data? (“Manner of
Collection of Personal Data”)
Directly through the contact form in our website which
will ask for your personal information together with your
inquiry or concern.
We also collect your personal information indirectly
through usage data (i.e. internet access logs) or cookies
(Please see Part I and II of this Privacy Policy).
When you access the ADEC Innovations website, your
Internet address is automatically collected and placed in
our access logs. One way we collect information is through
the use of cookies. Cookies are small files that save and
retrieve information about your visit to the ADEC
Innovations website such as how you entered and navigated
through our site. The cookies we use identify you by
number, not by name.
Do we share your information with third parties?
(“Disclosure of Personal Data to Third Parties”)
As a global organization, we may share your information
with employees of ADEC Innovations and third
party-stakeholders of our company, but only to the extent
necessary to address your inquiry or concerns. Such third
party-stakeholders may be located in other countries.
Before we do so, we shall take the necessary steps to
ensure that your personal data will be given adequate
protection as required by relevant data privacy laws in
the Philippines and in the territory of the third party,
as well as in accordance with ADEC Innovations’ internal
policies.
We also share your information through our third-party
cloud service provider, where your personal data are
stored in accordance with our instructions as Personal
Information Controller (PIC) and within the retention
limits set by our company. (see Part VI- Storage and
Transmission of Personal Data and Part VII – Retention of
Personal Data of this Privacy Policy).
How do you store and transmit personal information?
(“Storage and Transmission of Personal Data”)
A. Storage
-
We use a third-party cloud-based CRM platform to store
the personal data collected.
-
A unique account is registered through the CRM platform,
which is administered by our designated Customer
Relationship Management (CRM) Administrator. This unique
account is secured through a username and password known
only to the CRM Administrator.
-
The data collected from our website through the form
found therein are automatically transmitted to the
third-party CRM platform.
-
In addition to the storage in the third-party
cloud-based CRM platform, we store in an encrypted back
up in our company secure local server.
B. Transmission
-
Any personal data we collected is automatically
transmitted to our third-party cloud-based CRM platform.
-
Any personal data collected is likewise transmitted to
our employees who may have a legitimate interest over
the personal data, upon a written request by e-mail. The
CRM Administrator transmits encrypted personal data by
e-mail.
How do you store and transmit personal information?
(“Storage and Transmission of Personal Data”)
We retain your data for a maximum of two (2) years, after
which we delete or dispose of the same in accordance with
our personal data disposal or deletion policy.
Disposal of Personal Data Collected
Disposal of Personal Data Collected in our website through
our third-party storage platform and our back-up stored in
the CRM Administrator’s computer/laptop is done after two
(2) years from collection or upon request of the data
subject. Should we need to retain your data for a longer
period, you will be notified accordingly.
Our Data Privacy Compliance Office (DPCO) and DPOs monitor
and audit respective personal data’s maturity, collected
and stored and ensure that data reaching maturity of
retention period shall be reviewed for usefulness and
disposed of accordingly, following the company policies
and procedures in disposal of personal data, to wit:
(a) Our CRM Administrator is the person mainly responsible
to delete personal data upon its maturity or request of
the data subject. As a policy, all personal data collected
in our website are in digital format. These are deleted
through the third-party cloud-based CRM Platform by the
CRM administrator. A written report of deletion of
personal data (with details of the deletion, such as date,
time and place of deletion, persons present, manner of
deletion and description of the personal data deleted),
shall be accomplished by the CRM Administrator for
submission to the DPO.
(b) Our third-party cloud-based storage provider is also
notified through a request to be made by the CRM
Administrator of the maturity of the personal data
collected and/or the request made by the data subject,
with an instruction that the same should be deleted
permanently from their system. A written report shall be
required of the third-party cloud-based storage provider,
with details of the deletion, such as date, time and place
of deletion, persons present, manner of deletion and
description of the personal data deleted.
(c) As to the back-up copy of the personal data collected
stored in the laptop/computer of the CRM Administrator,
the same are deleted in the same manner as letter (a)
hereof.
Security Measures to Protect your Personal Data
We take appropriate steps to maintain the security of your
data on the ADEC Innovations website.
We are implementing organizational, physical, and
technical security arrangements for all the personal data
we hold. We have protocols, controls and relevant
policies, procedures, and guidance to maintain these
arrangements taking into account the risks associated with
the categories of personal data and the processing we
undertake.
We adopt organizational and market leading security
measures and technology, and maintain annual
certifications by leading authorities in compliance, in
order to protect your personal data, including but not
limited to:
A. Organizational Measures. Our company has appointed a
Data Protection Officer (DPO) and Compliance Office (COP)
to ensure compliance with DPA. We also ensure that all our
employees are equipped with knowledge on DPA, through
internal and external trainings and seminars. Our company
conducts Privacy Impact Assessment (PIA), especially for
our teams who handle the company’s website, to ensure that
personal data is protected at all times.
Access to personal data collected through our website are
granted only to authorized personnel. Each personnel with
access to personal data shall verify his or her identity
using a secure encrypted link and multi-level
authentication.
We ensure that a data sharing agreement, with specific
provisions on security measures to protect your data is
executed with our service providers, including our
third-party cloud-based service storage provider.
B. Physical and Technical Security Measures. The personal
data collected through our website are all in digital
format. Hence, we do not print collected data, nor do we
retain paper-based or hard copies thereof.
-
-
We review and evaluate software applications before
its installation in computers and devices owned by
the organization to ensure compatibility of security
features with the overall operations, including the
third-party cloud-service storage we use to store
the personal data collected through our website.
-
We review security policies, conduct vulnerability
assessments and perform penetration testing within
the company on a regular schedule to be prescribed
by our BTS & InfoSec department.
-
Encryption, authentication process, and other
technical security measures that control and limit
access to personal data are implemented. All files
with personal data collected are password-protected
and may only be accessed by authorized personnel.
A full and comprehensive procedure of these Security
Measures is available upon request.
-
We also subscribe to the following globally recognized
Quality Management Standards (ISO/IEC 9001) and
Information Security Management Standards (ISO/IEC
27001) and conform to globally accepted best practices,
to ensure personal data remain safe and secured while it
is processed with transparency, legitimacy and
proportionality to preserve its confidentiality,
integrity and availability, thereby upholding the data
privacy rights of our employees, customers and business
stakeholders. Our organization remains compliant and
ensures updated certification for ISO 9001, ISO 27001
and ISO 14001; and implements reasonable and appropriate
measures to protect personal data against natural
dangers such as accidental loss or destruction; and
human dangers such as unlawful access, fraudulent
misuse, unlawful destruction, alteration and
contamination:
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ISO/IEC 27002, Information Technology – Security
Techniques—Code of Practice for Information Security
Controls;
-
ISO/IEC 27003, Information Technology- Security
Techniques – Information Security Management System
Implementation Guidance;
-
ISO/IEC 27005, Information Technology – Security
Techniques – Information Security Risk Management;
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ISO/IEC 29134, Information Technology – Security
Techniques—Guidelines for Privacy Impact Assessment;
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ISO/IEC 29151, Information Technology – Security
Techniques—Code of Practice for personally
identifiable information (PII) protection;
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ISO/IEC 29100, Information Technology – Security
Techniques – Privacy Framework;
-
ISO/IEC 3100:2018 Guidelines on Risk Assessment; and
-
ISO/IEC 27018:2014 Information Technology- Security
Techniques—Code of Practice for protection of
personally identifiable information (PII) in public
clouds acting as PII processors.
While we use reasonable technical and administrative
measures within our means to protect your data against
unauthorized or unlawful use, processing, accidental loss,
alteration, disclosure or access, accidental or unlawful
destruction or damage thereto, you must understand that
the open nature of the Internet is such that data may flow
over networks without security measures and may be
accessed and used by people other than those for whom the
data is intended. Thus, please remember that no method of
transmission over the Internet, or method of electronic
storage is 100% secure and while we strive to use
commercially acceptable means to protect your personal
data, we cannot guarantee its absolute security.
What are your rights in relation to the processing of
your personal data?
The following are your rights subject to limitations set
by law:
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RIGHT TO INFORMATION This right
entitles you to know the specific personal data being
collected, the purposes for its processing.
-
RIGHT OF ACCESS This right entitles you
to know whether we hold personal data about you and, if
we do, to obtain information on and a copy of that
personal data.
-
RIGHT TO RECTIFICATION This right
entitles you to have your personal data be corrected if
it is inaccurate or incomplete.
-
RIGHT TO OBJECT This right entitles you
to object the processing of your personal data.
-
RIGHT TO ERASURE This right entitles
you to request the erasure of your personal data,
especially when it is no longer necessary to achieve the
purposes.
-
RIGHT TO RESTRICTION OF PROCESSING This
right entitles you to limit the personal data to be
processed.
-
RIGHT TO DATA PORTABILITY This right
entitles you to receive a copy (in a structured,
commonly used, and machine-readable format) of personal
data that you have provided to us or request us to
transmit such personal data to another data controller.
Withdrawal of Consent. Right to Complaint and
Damages
To the extent that the processing of your personal data is
based on your consent, you have the right to withdraw such
consent at any time by contacting ADEC Innovations’ Data
Protection Officer. Please note that this will not affect
ADEC Innovations’ right to process personal data obtained
prior to the withdrawal of your consent, or its right to
continue parts of the processing based on other legal
bases than your consent.
If, despite our commitment and efforts to protect your
personal data, you believe that your data privacy rights
have been violated, we encourage and welcome you to first
seek resolution of any complaint. You have the right, at
all times, to register or file a complaint directly with
the relevant supervisory authority (the National Privacy
Commission) or to make a claim against us with a competent
court (either in the country where you live, the country
where you work or the country where you deem that data
privacy law has been infringed), with a right to seek
damages.
For any concerns and request to exercise the foregoing
rights, except those which are within the jurisdiction of
the NPC or a competent court, you may contact us at
dataprivacyoffice@adec-innovations.com.