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RIGHTS OF THE DATA SUBJECT As a data subject, you have the following rights under the Philippines’ Data Privacy Act of 2012 – Republic Act 10173 (“DPA”) and the General Data Protection Regulation (EU) 2016/679 (“GDPR”), which this Policy and our use of personal data have been designed to uphold:
- The right to be informed about our collection and use of personal data;
- The right of access to the personal data we hold about you;
- The right to rectification if any personal data we hold about you is inaccurate or incomplete;
- The right to be forgotten or the right to ask us to delete any personal data we hold about you;
- The right to restrict or prevent the processing of your personal data;
- The right to data portability by obtaining a copy of your personal data to re-use with another service or organisation;
- The right to object against using your personal data for particular purposes; and
- The rights with respect to automated decision making and profiling.
CONTENT AND USE OF INFORMATION All information provided to this site shall be deemed and/or remain the property of Netbundy, and Netbundy shall be free to use, for any purpose, any idea, concepts, know-how or techniques contained in the provided information, subject to the provisions on privacy detailed herein. Except as specifically required by Philippine law, European Union law, and other international laws, Netbundy shall not be subject to any obligations of confidentiality regarding the provided information.By posting any content, you are granting permission to Netbundy and others to access and use it in connection with any service, the site, the device or kiosk, and otherwise in connection with our business. In connection with your posted contents, you agree that you will not: (1) submit material that is copyrighted, protected by trade secret, or otherwise subject to third party proprietary rights, including privacy and publicity rights, unless you are the owner of such rights or have permission from their rightful owner to post the material; (2) publish falsehoods or misrepresentations that could damage Netbundy or any third party; (3) submit URLs or contents that are unlawful, obscene, defamatory, libelous, threatening, pornographic, harassing, hateful, racially or ethnically offensive, or encourages conduct that would be considered a criminal offence, give rise to civil liability, violate any law, or is otherwise inappropriate; (4) offer or provide services whose subject matter is pornographic.Likewise, references to political activities, political party meetings, demonstrations, fliers or petitions, as well as the propagation of political symbols is prohibited. Furthermore, posted contents which insult, belittle, or in other negative ways affect other users are also prohibited. If you violate any of these restrictions, Netbundy is authorised to deny or delete your posted content and/or cancel your right to use the site, services, and/or devices, without prior notice. Netbundy may do so in its sole discretion without any obligation to investigate. You will be liable to Netbundy for all direct and indirect damages for any violation of the above-mentioned restrictions. You agree to indemnify Netbundy from all claims by a third party resulting from your violation of the above restrictions.
WHY WE COLLECT YOUR DATA We will use the information you provide us for the following purposes:
We use your collected information to personalise your repeat visits to the website and to administer and improve our services.For our policy on using your personal data for marketing purposes, please see the section on Promotional and Direct Marketing below.
- to provide timely, reliable, and value-added services to customers, including payroll, worker onboarding, contract management, timekeeping, reporting, and billing;
- to establish a customer relationship and to communicate with you;
- to process any transactions that you enter into with Netbundy and respond to any enquiries you may have;
- to meet requirements imposed by law; and
- other purposes directly relating to any of the above.
WHAT DATA WE COLLECT Depending upon your use of our site, services, and/or devices, we may collect some or all of the following personal and non-personal data:
Our device or kiosk is capable of processing biometric data (fingerprint only), but the user or data subject should give explicit consent to the processing of this personal data for the purposes of authentication, timekeeping, and/or attendance checking.We do not and we will not process other special categories of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership.
- company name;
- biometric data – fingerprint only;
- time entries;
- contact information such as email addresses and telephone numbers;
- demographic information such as address and location;
- device information such as device model, serial number, IMEI, battery level, WiFi signal;
- IP address;
- web browser type and version;
- operating system;
- a list of URLs starting with a referring site, your activity on our site, and the other site you exit to;
HOW WE USE YOUR DATA All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under DPA and GDPR at all times.Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
- providing and managing your account or profile;
- providing and managing your access to our site, services, and/or devices;
- personalising and tailoring your experience on our site, services, and/or devices;
- supplying our services to you;;
- personalising and tailoring our services for you;
- replying to emails from you or sent by you;
HOW AND WHERE WE STORE YOUR DATA We keep only your personal data for as long as we need to in order to use it as described above, and/or for as long as we have your permission to keep it.Your data will be stored only within the European Economic Area (“the EEA”), which consists of all EU member states, plus Norway, Iceland, and Liechtenstein. Data security is very important to us. In order to protect your data, we have taken suitable measures to safeguard and secure data collected through our site and services.
HOW YOU CAN ACCESS YOUR DATA The user or the data subject has the right of reasonable access, modification, correction, and removal of data collected on this site, under the conditions stipulated by the data privacy laws and regulations unless we have to keep that information for legitimate business or legal purposes.When updating your personal data, we may ask you to verify your identity before we can act on your request. Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge.We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system), risk the privacy of others, or would be extremely impractical.We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.
DISCLOSURE AND SHARING OF YOUR DATA We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.We may compile statistics about the use of our site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.In certain circumstances, We may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.
ONLINE PRIVACY We use online data collection tools to evaluate the effectiveness of our websites, improve functionality and enhance security. Like many organizations, we sometimes gather data, such as IP address, how visitors explore our websites, information about whether it is a new or a repeat visit, which pages the visitor explored and the length of the visit, the geographical location and similar details. All such information is collected in an aggregate form and is used to improve our websites’ functionality and performance so we can create a better experience for our visitors.
PROMOTIONAL AND DIRECT MARKETING From time to time, you may provide us with personal information for the purposes of helping us improve your overall experience with us or helping us provide relevant information about our products, services, and promotions.By providing us with this personal information, you consent to our use of your personal information for promotional or direct marketing activities by way of email, SMS, and post. We aim to give you strong controls on our use of your data for direct marketing purposes, including the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails or by sending an email to email@example.com with the word “REMOVE” in the subject line. If at any time you are unsure of how to access or correct your information, please contact us.
SECURITY The security of your Personal Information is important to us. We will make all the reasonable arrangements to ensure that the personal data in our possession or under our control are protected against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. In certain cases, your personal data will be encrypted during transmission using the Secure Socket Layer (SSL) technology. This means that the communication between your computer and our servers takes place using a recognised encryption method, provided that your browser supports SSL. However, remember that no method of transmission over the Internet, or method of electronic storage, is completely secure.Although we will do our best to protect your personal data, we cannot guarantee the absolute security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features in order to prevent unauthorised access.
CONTACT US You may contact our Data Protection Officer if you have any questions regarding Data Protection or Privacy and/or if you need to report a security incident.
- Address: 5/F, Exchange Corner Bldg. V. A. Rufino St. cor Esteban & Bolaños Sts. Legaspi Village, Makati City, Philippines
- Phone: +63 (02) 808-4707
- Email: firstname.lastname@example.org