Privacy Policy

Introduction

Eton Properties Philippines, Inc. (EPPI) and its subsidiaries, respect your privacy and recognize the need for appropriate measures to protect and manage your personal data entrusted to us. Our Privacy Policy follows, and is consistent with, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), other issuances of National Privacy Commission (NPC), as well as other relevant laws of the Philippines.

Personal data refers to all types of personal information, sensitive personal information and privileged information. Personal information refers to “any information, whether or not recorded in any form, from which the identity of an individual is apparent or can reasonably and/or directly be ascertained by the entity holding the information, or, when put together with other information, would directly and certainly identify an individual”.

This Privacy Policy pronounces how EPPI process (how it collects, uses, shares, and retains) and protect your personal data. It also provides the steps that you can take should you wish for any change in how we use your personal data, or if you want us to stop using your personal data.

Why do we collect your personal data?

To enable us to comply with our corporate policies in relation to data subjects as well as with the requirements under the Data Privacy Act, it is important that we collect, use, store and retain your personal data only as is reasonable and necessary for a declared and specific purpose stated in the pertinent consent forms.

In general, we are using your data for any of the following purposes:

To provide information about our products and services which may be of interest to you;
To perform functions necessary to deliver the services, goods and other products offered by EPPI;
To conduct research and analysis (through surveys or polls) in order to improve customer experience/satisfaction;
To respond to specific complaints, inquiries, requests or manage future interactive user function it may be necessary to ask for personal information;
To provide customer care activities, monitor our quality and security, and provide services timely and efficiently;
To generate statistical insights;
To notify and update you (through call, text or email) about our complimentary, commercial and promotional advertisements, loyalty and rewards offers, exclusive invites, discounts, surveys, and other direct marketing that we deemed relevant and beneficial to you based on your preference and interest initially provided to us or made aware of, with which you can opt-out anytime should you prefer not to receive these notifications;
Allows us to personalize the site for the user and view how and when specific users visit the site, helping us to improve the site. The use of cookies is an industry standard. Cookies are stored on your computer and are used only to view information on your hard drive that was put there by a cookie from this site. If you do not wish to receive cookies you may set your web browser to prevent them;
To comply with legal and regulatory requirements or obligations; and,
To perform such other processing or disclosure that may be required under law or regulations.

Other uses by nature of our transactions

In addition, we may use your personal information depending on your transactions with us in any of the following means:

A. When you want to become a part of our team:

To consider and evaluate your suitability for employment and, with your permission, inform and consider you for future job opportunities that may be of interest to you;
To communicate with you about your employment application;
When hired, to process your data necessary for your employment such as, but not limited to, payroll, benefits application, allowances and refunds processing, tax processing, retirement benefits, and other purposes that demand processing of your personal data (e.g., business travels, anniversaries, social activities, emergencies, and so on);
When hired, for your performance evaluation and career development including seminars, trainings, workshops, and compliance monitoring,
When hired, to process your data necessary to execute business transactions such as preparation and/or approval of business documents and any other functions that are directly related and/or incidental to your job and that will demand processing of your personal data; and,
Upon separation, to process your data for the exit interview and preparation of final pay.

B. When you inquire or acquire a property:

To assist you in your property investment
To conduct appropriate credit investigation to assess the risk of you defaulting on your obligations to EPPI;
To administer the sale of residential units and prepare all necessary sales documentation as a result of our transaction;
To execute contract or provide information/services concerning the trading, brokerage, leasing, management and other incidental operations of real estates;
To process and respond to any complaints, inquiries and requests made by you;
To update our records and keep your contact details and billing address up to date;
To manage all administration of unit hand over activities;
To perform all financial processes related to the sale including set-up of reservation, amortization or financing and perform other actions necessary or desirable in the implementation of our contract;
To provide safety and security to the unit owners, tenants and employees of tenants/unit owners; and,
To perform other processes related to or in connection with our business, including those processing or disclosure that may be required under law or regulations.

C. When you apply to become a tenant or merchant in any of our properties for lease:

To evaluate the interest of a party in a commitment to lease a space;
To assess if lessee’s concept and space required is agreeable to the terms and conditions of EPPI;
To conduct appropriate credit investigation to assess the risk of you defaulting on your obligations to EPPI;
To prepare lease contract and other documentations as may be required and necessary in the consummation of contract;
To perform all relevant financial transaction such as processing of security deposits, advanced rental payments, monthly rental payments and other incidental charges as included in our contract;
To provide safety and security to the unit owners, tenants and employees of tenants/unit owners;
To communicate any advisories, or changes in terms and condition related to your lease contract; and,
To perform other processes related to or in connection with our business, including those processing or disclosure that may be required under law or regulations.

D. When you are a vendor, a potential vendor, or a contractor:

To conduct appropriate due diligence checks;
To evaluate your proposal including your manpower, technical and operational capacity;
To assess the practicability of your proposal and process your accreditation;
To communicate the result of your proposal and to execute a letter of award together with the contract;
To perform any other action as may be necessary to implement the terms and conditions of our contract; and,
To perform other processes related to or in connection with our business, including those processing or disclosure that may be required under law or regulations.
To contact you when we require your services

E. When you are a retail customer:

To provide necessary services that suits your needs and preferences as customer of our retail products;
To process your entry in relation to our raffle promotion. Also to inform you in the event you have won the raffle and use your information to be featured in any publicity materials connected to the raffle promo;
To perform other processes related to or in connection with our business, including those processing or disclosure that may be required under law or regulations.

F. When you apply for broker accreditation:

To consider and evaluate your suitability for broker accreditation and, with your permission, inform and consider you for future job opportunities that may be of interest to you;
To communicate with you about your broker accreditation;
To expedite your application and start to work with us.

G. When you have a message for property management:

To address your concerns and assist you with your property needs

What type of personal data do we collect?

We collect information to provide you with details and information regarding our product, services, and promotions; as well as to cater to your particular needs and interests through tailor-fitted services and solutions. We process information also to respond to your inquiries or manage future interactive user function. The common type of data collected by EPPI from you, generally includes the following:

Personal information such as full name, nickname, home addresses/billing address/shipping address, e-mail address, employment information, telephone, other personal contact numbers, username and password;
Sensitive personal information such as age, nationality, marital status, gender, health, education and government issued identification document which includes, but not limited to identity (ID) cards, licenses, social security number;
Employment record such as educational background, employment history, certifications, trainings attended, resume and income information of your previous jobs;

You are responsible for ensuring that all data, whether personal information, sensitive personal information or privileged information, you submit to EPPI is accurate, complete and up-to-date.

How we collect, acquire or generate your data?

We collect data when you:

Submit a job application;
Submit a proposal and related business documents;
Fill-out our forms and submit necessary documents;
Submit information through any form on our digital platforms or contact us through any of our social media accounts, as well as from the online retail marketplace.
Purchase or avail of any of our properties, products, services and promos;
Respond to surveys, promotions, and other marketing and sales initiatives;
Provide personal information in relation to inquiries, requests, and complaints
Subscribe to our newsletter by indicating your email address; and,
Disclose your personal information through phone calls, emails, SMSs or verbal communication with our authorized representatives.

Do our websites use web analytics?

This service does use cookies or web beacons.

Cookies are small files that our website puts on your browser to store information about your preferences. Cookies can improve your browsing experience by allowing our website to remember your preferences or letting you avoid signing in each time you visit our website. If you don’t want our website to store cookies on your PC, you can block cookies. But blocking cookies might prevent some pages from displaying correctly, or you might get a message from our website letting you know that you need to allow cookies to view our website.

For you to fully enjoy your visit and browsing experience, only unidentifiable web traffic data are collected and analyzed, including:

Your internet protocol (IP) address;
The search terms you used;
The pages and internal links accessed on our site;
Demographics limited to the date and time you visited the site, including frequency of visits;
Geolocation;
Your operating system; and
Web browser type.

Use the options in your web browser if you do not wish to receive cookies or you wish to set your browser to notify you when you receive cookies. Click on the “Help” section of your browser to learn how to change your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features of this website.

What about the links to third-party websites?

From time to time, we will provide links to third-party web sites, or advertisements which contain links to third-party sites. These links are provided as a service to you and we do not provide any personal data to these websites or advertisers, and therefore, we will not accept responsibility for their privacy practices. These sites are operated by independent entities that have their own privacy policies which you should review as well. EPPI’s Privacy Policy does not apply to such other sites or to the use that those entities make of your information. EPPI has no control over the content displayed on such sites, nor over the measures, if any, that are taken by such sites to protect the privacy of your information.

Who do we share your personal data with?

As a general rule, we are not allowed to share your data to third party entities, except in limited circumstances as listed below.

By giving your consent, you authorize EPPI to disclose your personal data to accredited/affiliated third parties or independent/non-affiliated third parties, whether local or foreign in any of the following circumstances:

As necessary for the proper execution of processes related to the purposes declared in this Privacy Policy.
The use or disclosure is reasonably necessary, required or authorized by or under law (such as for criminal investigation, as requested by court of law).

This means we might provide your personal data to the following:

Our affiliates, subsidiaries, partner companies, organizations, or agencies including their sub-contractors or prospective business partners that act as our service providers and contractors;
Law enforcement and government agencies;
All third parties, as noted in Annex A, with which we share this personal data are required to use your personal data in a manner that is consistent with this Privacy Policy.

However, these companies may only use such personal data for the purposes disclosed in this Privacy Policy and may not use it for any other purpose.

What is our Privacy Policy regarding children?

EPPI is very sensitive to privacy issues and it is especially careful in its communications with children. EPPI would never directly collect personal data from children without the parent’s consent.

Personal data pertaining to children and collected from their parents is used by EPPI or other entities that provide technical fulfillment or other services to EPPI (for example, services intended to improve our services/web sites, and fulfilling requests or administering promotions). These personal data are not sold.

Meanwhile, we urge parents to regularly monitor and supervise their children’s on-line activities.

How we protect your personal data?

We take reasonable steps to ensure that the personal data we collect, use or disclose are accurate, complete, and up-to-date. We strictly enforce this Privacy Policy within EPPI and we have implemented technological, organizational and physical security measures to protect your personal data from loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction. We put in effect safeguards such as the following:

We keep and protect your personal data using a secured server behind a firewall, deploying encryption on computing devices and physical security controls.
We restrict access to your personal data only to qualified and authorized personnel who hold your personal data with strict confidentiality.
Any personal data that you provide on https://eton-uat.purplebugprojects.com/ is initially processed and stored by the website. Using a secured connection, only authorized EPPI personnel can then access and download your personal data from the system.
It is important for you to protect against unauthorized access to your password and to your device. Be sure to sign-off when finished using a shared computer.

Where and how long do we keep your personal data?

All data are preserved in accordance with the following retention standards:

If the data subject has an existing contract and transaction with EPPI, the information will be retained all throughout the contract period and 10 years after its completion.
If the data subject has no existing contract but has existing transaction with EPPI, the information will be retained during the transaction and 5 years after its fulfillment.
If the data subject has no existing contract and transaction with EPPI, the information will be retained for a period of 2 years.

Personal data are stored in our facilities located in the Philippines and are retained in accordance with the above parameters, industry standards, laws and regulations, unless you request that your personal data be deleted from our systems, databases and hardcopies immediately. Once deleted, your personal data will no longer be searchable or included in anonymous searches and will be completely removed from all the storage location

The Data Privacy Officer may, however, choose not to grant access or correct information based on the request following laws and regulations. He/she will give the individual a written notice that sets out the reason for the refusal.

What if there are changes in our Privacy Policy?

EPPI may revise this Privacy Policy as the need arises or when dictated by issuances of the National Privacy Commission or any amendment to the Data Privacy Act. Any change to this Privacy Policy shall be duly posted in this website and will take effect immediately. Data subjects are encouraged to periodically check for such updates. Changes shall not be retroactively applied and will not alter how we handle personal data previously collected without obtaining your consent, unless required by law.

How you can access, correct and update the personal data we have about you?

To exercise your rights which include right to access, modify, erase and object to processing your personal data within a reasonable time after such request or should you have any inquiries, feedbacks on this Privacy Policy, and/or complaints to EPPI, you may reach us through our “Contact Us” menu in this website: https://eton-uat.purplebugprojects.com/ through a written letter or through an email to our Data Protection Officer (DPO).

Our contact details are as follows:

Data Protection Officer

8F Philippine National Bank (formerly Allied Bank Center)

6754 Ayala Avenue, Makati City, Philippines

dpo@eton-uat.purplebugprojects.com

You may also lodge a complaint before the National Privacy Commission (NPC). For further details, please refer to NPC’s website: https://privacy.gov.ph/mechanics-for-complaints/.

Any action to a request for correction, erasure and/or objection to process your personal data as it appears in our records is subject to applicable laws and/or the DPA, its IRR and other issuances of NPC.