A.
PRIVACY STATEMENT
ENTREGO FULFILLMENT SOLUTIONS INC. (“ENTREGO”) acknowledges the necessity and importance of
promoting a data privacy culture across the organization and the imperative
protection of the rights and privacy of every individual in adherence to the
general principles of transparency, legitimate purpose, and proportionality. We
are aware of our duties and responsibilities in securing and protecting the
data collected from our customers, vendors, partners, employees, agents, and
other stakeholders and the processing thereof.
In processing your
personal data or information, Entrego shall comply with the Data Privacy Act of
2012 (“Data Privacy Act”), its implementing Rules and Regulations (“IRR”), and
other relevant policies and issuances of the National Privacy Commission
(“NPC”).
B.
SCOPE
1.
This Policy applies to
the collection, use, storage, transfer, and destruction of all personal data
collected and processed by the Company.
2.
ENTREGO reserves the
right to modify/amend this Privacy Policy in accordance to data privacy
regulations at any time.
C.
DEFINITION OF TERMS
|
Data Subject |
Employees,
customers, suppliers, or other external parties whose personal data are
processed by the Company |
|
Data Sharing Agreement
|
Contract,
joint issuance, or any similar document that contains the terms and
conditions of a data sharing arrangement between two or more personal
information controllers |
|
Personal Data |
Collective
term for personal information and sensitive personal information, including
privileged information |
|
Personal Information |
Any
information from which the identity of an individual can be reasonably and
directly determined, or when put together with other information could
certainly and directly identify an individual |
|
Personal Information Controller (PIC) |
Any natural or
juridical person or any other body who controls the processing of personal
data, or instructs another to process personal data on its behalf. The PIC is
the Company |
|
Personal Information Processor (PIP) |
Any natural or
juridical person, or any other body to whom a personal information controller
may outsource or outsources the processing of personal data |
|
Processing |
Any operation
performed on personal data including, but not limited to, collection,
recording, organization, storage, updating or modification, retrieval,
consultation, use, consolidation, blocking, erasure or destruction of data |
|
Sensitive Personal Information |
Personal
information that is:
1.
About an individual’s
race, ethnic origin, marital status, age, color, religious, philosophical or
political affiliations;
2.
About an individual’s
health, education, genetic or sexual life, or any proceeding for any offense
committed or alleged to have been committed by such individual, disposal of
such proceedings, or sentence of any court in such proceedings;
3.
Issued by government
agencies peculiar to an individual which includes, but not limited to, SSS
numbers, previous or current health records, licenses or its denials,
suspension or revocation, and tax returns; and
4.
Specifically
established by an Executive Order or an act of Congress to be kept classified
|
D.
COLLECTION AND USE OF
PERSONAL DATA
- When
do we collect Personal Data
Information is collected from you when:
a.
You sign up for our
services;
b.
You request assistance
from our customer support team;
c.
You apply for a job, or
participate in activities where we may require information about you;
d.
You complete surveys, or
request other information from us.
- Data or Information Collected
We collect and process the following types of personal data,
among others:
a.
Service Usage of Website
Data which includes the time of use/interaction, interaction with the features,
contents and links; browser type and configuration, and IP addresses, links
visited, browsing activities;
b.
Account Related
Information upon signing up for our Services which includes full name, address,
mobile/phone number, and email address.
c.
Employment Related
Information which includes contact information, employment/
business/organizational affiliation, personal details, employment history,
educational background, biometric information, filial relations, gender, date
of birth, religion, ethnicity, civil status, citizenship, physical medical
history, administrative/criminal records, copies of government issued IDs,
payroll information.
d.
Business Related
Information which includes contact information and employment and/or business
affiliation of our clients and officers/employees representing or affiliated
with our partners, suppliers, vendors, investors or other business contacts,
credit history, bank account information, Securities and Exchange Commission,
Department of Trade and Industry, Bureau of Internal Revenue documents,
clearance, and permits issued by government agencies.
- Purpose of Collection
ENTREGO collects and process data for the purposes of
operating the Website, delivering the services you have requested, and
complying to applicable laws, rules and regulations.
a.
Investors, Partners, Client, and other Business
Contracts
i.
For purposes of conducting
accreditation, background investigation, and due diligence;
ii.
For purposes of
fulfilling its duties and responsibilities under the contracts;
iii.
For purposes of
protecting and defending Entrego’s rights under the laws.
b.
Employees, Consultants,
Independent Contractors
i.
For the purposes of
background investigation (i.e. identifying the identity and qualification of
the employees or applicant);
ii.
For Human Resource and
Administrative Department’s Records (i.e. required staffing, alignment of
qualifications to vacancies);
iii.
For purposes of
complying with the contracts and fulfilling its obligations with the government
agencies (i.e. BIR, SSS, PhilHealth, Pag-ibig); and
iv.
For purposes of
protecting and defending Entrego’s rights under the laws.
E.
HOW WE COLLECT AND
PROCESS PERSONAL DATA
- We collect information when you visit our websites,
sign up to receive communication from us, avail any of our
products/services.
- Directly from the job applicants and employees through
their voluntary submission of their curriculum vitae (resume), certificate
of employment from previous employers, personal data sheets, medical
records (for pre-employment health screening), government documents (i.e.
BIR Form 2316, National Bureau of Immigration clearance, Police Clearance,
etc.)
- Directly from the clients, partners, and contractors
through their voluntary submission of documents/information needed for the
purpose of complying with the terms and conditions of the contracts.
F.
DISCLOSURES OF
INFORMATION
ENTREGO do not sell, rent, or lease the personal data it
processed. It will not disclose such information to any person unless with
consent of the Data Subject and legally bound to do so by the legal
authorities. However, ENTREGO allows the access to personal data to authorized
third-party service providers/suppliers/subcontractors/consultants who provide
outsourced functions including, among others:
- Automated payroll processing and management to ensure
timely and proper compensation as wells as compliance to existing
employment regulations;
- Automated and manual human resource database and
benefits management systems;
- Online Portal/Application-based facilities;
- External professional advice and consultation including
audits, legal assessments, comparative compensation studies and
evaluations; and
- Other financial, technical, and administrative services
such as information technology, payroll, accounting, sales administration,
procurement, training and other services.
ENTREGO remains responsible over the above personal data
disclosed to such third parties. As such, we ensure that such third parties are
contractually obligated to comply with the requirements of the Data Privacy act
and shall process your data strictly in accordance with the purposes enumerated
above.
G.
THE RIGHTS OF DATA
SUBJECT
- Right to be Informed
They have the right to be informed whether personal data
pertaining to them shall be, are being, or have been processed, including the
existence of automated decision-making, profiling, processing, storage,
retention, disposal.
- Right
to Object
They have the right to object to the processing of their
personal data which may include suspension, withdrawal, and request for
destruction of personal date in the possession of the Company which are
unlawfully processed.
- Right
to Access/Rectification
They have the right to have access their data upon
reasonable demand and rectify the errors, if any.
- Right
to Dispute
They have the right to dispute any errors, mistakes,
inaccuracy in the data processed by the Company.
H.
POLICY ON THE COLLECTION
AND USE OF PERSONAL DATA
1.
Collection of Personal Data
Collection of personal
data is made whenever necessary to carry out the purpose for which the personal
data are intended through lawful and fair means, and where appropriate, with
notice to, or consent of, the data subject concerned. As such, ENTREGO may require
personal data from the data subjects in order to:
a.
Verify the data
subject’s identity among others;
b.
Perform contractual or
any legal obligation of ENTREGO to the data subject;
c.
Process the necessary
legal requirements of ENTREGO;
d.
Protect the interests of
the data subject, including his/her life and health;
e.
Process any request by
the data subject to ENTREGO;
f.
Gain understanding of
the data subject’s preferences in order to enhance ENTREGO’s products and
services;
g.
Maintain records that
are deemed necessary in case of investigation and resolution of litigations;
and
h.
Pursue the legitimate
interests of ENTREGO, or a third party to whom the personal data are disclosed,
except where such interests overridden the fundamental rights and freedom of
the data subject.
2.
Uses of Personal Data
Collected personal data are used solely in a manner compatible
with the declared, specified, and legitimate purpose. ENTREGO may require the
processing of personal data for other purposes but shall do so as permitted by
law or consented to by the data subject.
3.
Obligations in the Collection and Use of
Personal Data
a.
To fully inform the data
subjects of ENTREGO’s processing activities and data subjects’ rights;
b.
To obtain their consent
in accordance with the Data Privacy Act and other issuances;
c.
To ensure that Data
Subjects have an avenue to dispute any errors or inaccuracy in their personal
data, object to the changes in the information and purpose on which they are
being processes;
d.
To ensure that Data
Subjects can reasonably access, review, request for amendment of their personal
data and request for the deletion and destruction of the data unlawfully
processed.
I.
DATA PROTECTION OFFICER
ENTREGO has appointed a Data Privacy Officer (“DPO”) to
manage and protect the handling of personal data processing activities. Should
you have any concerns regarding the Company’s Data Privacy policies and
practices, you may contact the DPO through the following contact information:
|
Data Privacy Officer |
|
|
Contact Information |
Email: dpo@entrego.com.ph |
|
Office Address |
2nd Level, B6 Bonifacio Highstreet, Bonifacio Global City, Taguig City |
J.
PERSONAL DATA SECURITY POLICY
1.
Integrity of Personal Data
Personal data under the
control or custody of ENTREGO are kept current and complete to the extent
necessary for the purposes of use.
2.
Storage of Personal Data
ENTREGO ensure that all
personal data stored by organization, whether in manual or electronic form, are
kept in secure data centers with appropriate physical, technical and
organizational security measures and accessed in accordance with the data
security standards. The Company implements reasonable and appropriate security
measures to maintain the confidentiality, availability and integrity of
personal data and protect them against any accidental or unlawful destruction,
alteration, and disclosure, as well as against any other unlawful processing.
3.
Retention of Personal Data
Personal data are retained
only for as long as necessary for:
a.
the fulfillment of the
declared, specified, and legitimate purpose,
b.
the establishment,
exercise, or defense of legal claims, and
c.
legitimate business
purposes which are consistent with the industry standards followed by ENTREGO
or approved by appropriate government agency. ENTREGO may retain personal data,
but only as permitted by law.
4.
Disposal or Destruction of Personal Data
Personal data are
disposed of or discarded in a secure manner to prevent further processing,
unauthorized access, or disclosure to any other party or the public or
prejudice the interests of the data subjects.
K.
THIRD-PARTY DISCLOSURES
- When personal data are to be shared with or transferred
to another organization, whether domestic or international, the consent of
the data subject is obtained. ENTREGO exercises due diligence and takes
reasonable steps to ensure that the recipient will protect the personal
data consistent with these principles. ENTREGO may share personal data but
it shall only do so as permitted by law.
- In case the subcontracting of processing of personal
data is deemed necessary, ENTREGO
uses reasonable means to ensure that subcontractors have proper
safeguards in place to protect the confidentiality, integrity, and
availability of the personal data processed, prevent its use for
unauthorized purposes, and generally, comply with the requirements of the
Data Privacy Act, the Implementing Rules and Regulations, other applicable
laws for processing of personal data, and other issuances of the NPC.