PRIVACY POLICY

JINS Philippines Inc. (“Company”, “we”, “us”, or “our”) respects and values the privacy of its customers and stakeholders. We are committed to complying with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulation (“IRR”), other relevant laws of the Philippines and issuances of the National Privacy Commission (“NPC”) (collectively, the “Privacy Laws”). This Privacy Policy (“Policy”) details how the Company collects, processes, uses, stores, discloses, transfers, and disposes of the Personal Data shared with us, including the measures taken by the Company to protect and secure the Personal Data collected and processed, and steps undertaken to ensure that the rights of data subjects are upheld and observed.

From time to time, it may be necessary for the Company to request and receive Personal Data, defined and described below, in connection with the following activities, namely:

• accessing our Company website and portals, which includes browsing through any of our websites or mobile applications;
• visiting our physical branches;
• participating in gatherings and events organized or sponsored by our Company; and
• any and all direct or indirect dealings with our Company, our officers and employees, as an investor, a shareholder, job applicant, an employee or consultant, a stakeholder, a customer, or in any other relevant capacity, including but not limited to invitations for polls and surveys circulated via electronic emails.

At all times, prior to every instance of collection and processing, the Company ensures that it will obtain the consent of data subjects and will sufficiently provide such data subjects with all necessary information outlined below and required by the Privacy Laws.

We may collect and process Personal Data from data subjects in the ordinary course of our business or to the extent necessary to respond to requests, queries, and concerns of its customers, personnel, and stakeholders which may include, basic information such as the name, residence, and contact details of data subjects; sensitive personal information such as the age, financial information, biometric data, birthdate of data subjects; educational background, ID with picture, employment history, gender, government issued identifications, licenses, and certifications, health data (medical history, data on disability, medical diagnosis, opinions, fitness apps, vascular scan), marital status, photograph, place of birth, proceeding for any offense committed or alleged to have been committed by an individual, signatures, social security number, tax identification number, tax returns, titles and other evidence of ownership, among others. When a data subject visits our websites or uses any of our mobile applications, other data, such as browser type, operating system, IP address, domain name, number of times the website or the mobile application was accessed, including the frequency of such access, may be collected via cookies and other tracking technologies, such as transparent GIF files. Aggregate Information, or non-personally identifiable and anonymous data, such as how many times a data subject logs onto our websites or mobile applications may also be collected. The transmission of such personal data is implicit in the use of web communication protocols or is useful for the improved management and optimization of the data and electronic mail sending system.

A cookie is a small file which asks permission to be placed on a computer’s hard drive. Cookies allow websites to recognize a computer upon return of the user, enabling it to display personalized settings and other user preferences. It also allows websites to respond to data subjects as an individual. The websites and apps can tailor operations to a data subject’s needs, likes and dislikes by gathering and remembering information about their preferences. We use traffic log cookies to identify which pages are being visited. This helps us analyze data about webpage traffic and improve our website in order to tailor it to a data subject’s needs. We only use this information for statistical analysis purposes after which, the data is removed from the system. In general, cookies help us provide customers with a better website, by enabling us to monitor which pages customers find useful and which they do not. A cookie in no way gives us access to a data subject’s computer or any information about the data subject, other than the data the data subject chooses to share with us. The data subject will be given the opportunity to accept or reject the use of cookies on our websites in a pop-up box when the data subject first accesses our website. Once agreed, the file is added and the cookie helps analyze web traffic or lets a data subject know when you visit a particular site. Most web browsers, however, automatically accept cookies, but a data subject can usually modify their browser setting to decline cookies. The data subject may choose not to accept cookies; however, this may restrict the services that the data subject can access at our websites. Declining cookies may also prevent the data subject from taking full advantage of our websites.

When necessary, we request for a data subject’s Personal Data for us to understand the data subject’s needs and provide the data subject with better service. We will process such Personal Data for specific purposes and only where there is a specific legal basis for doing so as laid down by the Privacy Laws. Specifically, we will process Personal Data for the following purposes:

We collect and process the Personal Data provided via electronic mail or as provided in physical documents disclosed and transmitted. Personal data collected may be recorded and stored in both digital or electronic format, and in physical copies. Access to information is limited to authorized officers and personnel for the purpose of a data subject’s engagement and through their transactions with us. We may organize or consolidate the above-enumerated Personal Data to allow us to use the same for the foregoing purposes. We may also retrieve any of the data subject’s stored data for the same purposes, as well as to update, modify or correct your data upon your request. In all instances, the Company ensures that collection and processing are not undertaken through use of deceptive design patterns.

Any access to Personal Data will be limited to the person who requires your Personal Data to perform the functions for collection has been undertaken, and as required or allowed by law. We do not sell, trade, or otherwise transfer your Personal Data to third parties without a data sharing agreement compliant with the Privacy Laws. We will comply with the data sharing provisions of the Privacy Laws or obtain your prior consent, as may be necessary, should we share your Personal Data to third parties. Any data sharing for commercial purposes will be covered by a data sharing agreement.

We are committed to ensuring that Personal Data is kept secure. We have implemented suitable and adequate organizational, physical and technical security measures, policies and procedures intended to reduce the risks of accidental destruction or loss, the unauthorized disclosure or access to such information which are appropriate and adequate to the nature of the Personal Data we collect, and such other data breaches and security incidents as defined under the Privacy Laws. We implement the appropriate disposal (physical or electronic) policies for documents, records, and assets to ensure that Personal Data are disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public, or prejudice the interests of the data subjects. We may retain Personal Data only for as long as necessary for legitimate business purposes in line with the principle of proportionality, to comply with laws, regulations, or lawful court order, or to establish or defend a legal action.

We may amend or update this privacy policy from time to time as may be necessary. We recommend that you check this privacy policy every time we advise of any change. We will secure consent anew and prior to any acts of processing, in case of any amendments on the scope, purpose, nature, and extent of the processing which have been previously disclosed to data subjects.

Based on the provisions provided under the Privacy Laws, we uphold the following rights of data subjects, namely:

Data subjects are entitled to request that we:

If a data subject has questions, concerns, complaints, or suggestions regarding our compliance with the Privacy Laws or if they wish to exercise their rights to access, rectification, object, portability, or deletion in instances allowed under the law, they may contact us through our Data Privacy Officer as follows:

We will make every reasonable effort to correct, update and respond to requests promptly, unless we require further information from the data subject in order to fulfill a request, and in each case, subject to legal and other permissible considerations. We will also investigate and endeavor to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the Privacy Laws and other data privacy and protection policies we have put in place. A data subject shall have the option of referring to the NPC any complaint that cannot be resolved with us directly.