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Privacy Policy

Privacy Policy

SM Investments Corporation complies with the standards and requirements set forth by the Data Privacy Act of 2012, its Implementing Rules and Regulations, and other data privacy and guidelines issued by the National Privacy Commission.

We respect and value your personal information and data privacy rights and are committed to securing and protecting them against all unauthorized third parties. For that purpose, we implement the necessary and industry-standard organizational, physical, and technical security measures to maintain the confidentiality, integrity, and availability of your personal information.

This Privacy Policy will inform you on how we collect and handle your personal information or data and our practices to ensure that your personal data are protected and is inaccessible by unauthorized persons.

DEFINITION OF TERMS

In order to have a better understanding of this Policy, the following words shall be defined as follows:

  1. “Data Subject” – refers to an individual whose personal or sensitive personal information is collected, used, shared or otherwise processed.
  2. “DPA Legislation” – shall refer to the Philippine Data Privacy Act of 2012 (R.A No. 10173), its implementing rules and regulations and amendments and such other issuances of relevant government agencies on data privacy
  3. “Process”, “Processes”, “Processing” or “Processed” – shall have the meaning as defined by existing and future DPA Legislation
  4. “Personal Data” – any data, from which an individual person can be identified or ascertained; or from that data and other information which may be accessed. It includes personal information or sensitive personal information.

HOW AND WHEN WE COLLECT YOUR PERSONAL DATA:

We may collect your personal data when you:

  1. Visit our office and you logged in your name and address with our lobby or security personnel. We also collect CCTV footages as part of the security measures our office implements.
  2. Visit our website. We collect computer data, such as cookies, to enable you to browse and navigate through our website with ease.
  3. Submit your resume, curriculum vitae or other requirements for employment personally or through our website.
  4. Submit inquires through our website.

WHAT PERSONAL DATA DO WE COLLECT:

The following are the personal data we collect

  1. Name
  2. Address
  3. Email address
  4. Contact number
  5. Company
  6. Identification (ID) number
  7. CCTV Footage
  8. Personal information in a curriculum vitae
    • Full name
    • Address
    • Contact number
    • Date of birth
    • Gender
    • Marital status
    • Photograph
    • Number of children
    • Religion
    • Health Status
    • Educational background
    • Employment background
    • Seminars and trainings attended
    • Identification (ID) number(s)

PURPOSES OF DATA PROCESSING:

We may use the information that we collected for the following purposes:

  1. As part of our security protocols
  2. To enable us to properly address your inquiry or concern
  3. To enable you to browse through our website
  4. To enable us to analyze your web browsing behaviors
  5. To process your employment application
  6. To protect your personal data from unauthorized access

DATA SUBJECT CONSENT

We will only process your personal data after obtaining your consent. Your consent will be required to enable us to process your personal data for the purposes provided in this Policy.

In giving your consent, you agree that SMIC may collect, store or process personal data obtained from you for any or all of the purposes provided herein. You also agree to the sharing of your personal information to SMIC’s subsidiaries, affiliates, and third-party service providers and authorize them to process your personal data for the purposes provided in this Policy and other legitimate business purposes or to secure all personal information obtained from you against any unauthorized third party.

You may withdraw your consent by contacting the SMIC Data Protection Officer (DPO) in the contact details provided in this Policy.

COOKIES

We collect computer cookies to enable you to browse our website and to enable us to address your concerns and inquiry better. We utilize two major kinds of cookies as described below.

Necessary Cookies

These cookies are essential to enable you to browse our website and use its features. These cookies are stored on your browser as they are essential for the working of the basic functionalities of the websites.

Third-Party Cookies

We utilize these cookies to help you browse our website in a more personalized manner for your better convenience and experience. These cookies will be stored in your browser only after we have obtained your consent.

Consent on Cookies

You may withdraw your consent by choosing the opt-out function in our cookie setting. However, by opting out of these third-party cookies, your browsing experience may be affected. You may also later opt-out from said third-party cookies after giving your consent by clearing your cookies and other site data in your browser settings.

DATA SECURITY AND STORAGE

We have in place industry-standard organizational, technical and physical security measures to protect the confidentiality, integrity, and availability of personal data you provide and we collect.

Only authorized Company personnel has the access to the personal data that we collect from you. We have instituted policies and procedures to ensure that the personal data collected from you are safeguarded against unauthorized access, alteration, and disclosure. Security clearances and access rights are reviewed regularly to ensure that the controls are in place.

SMIC’s website is scanned on a regular basis. In addition, all sensitive information you supply is sent through a secured channel. SMIC implements a variety of security measures and maintains strict protocols on who can access your information to maintain the safety of your personal data.

Your personal data are stored in a secure facility and manner within the Philippines wherein unauthorized third-party will not have access. Should there is a need to process or transfer your personal data outside the Philippines for the purposes provided in this Policy, we will comply with the requirements of DPA Legislations for such processing or transfer.

DATA SHARING

SMIC will not share or disclose your personal data to any third party except to its subsidiaries, affiliates or third-party service providers in line with the purposes stated in this Policy. We likewise require said parties to implement strict data privacy measures in order to protect your personal data against unauthorized third-party access.

We may also share your personal data in compliance with applicable laws or when required by the courts, a competent government office, or an agency pursuant to DPA Legislations and other relevant rules and regulations pertaining to data privacy.

DATA RETENTION AND DISPOSAL

We will retain and store your personal data for as long as the purpose(s) of its processing subsists. We may also retain your personal data in order to enforce our legal rights or whenever it is required under DPA Legislation or upon lawful order of a competent court or relevant government agency.

Your personal data will be disposed of with proper security protocols when the purpose for which it was collected is fulfilled.

You may exercise your right to deletion and request for the return or deletion of your personal data by contacting our DPO in the contact details provided in this Policy.

YOUR OBLIGATIONS AND RIGHTS

You are responsible for ensuring that the personal data you provide is accurate and up-to-date. You can update your personal data anytime by contacting our DPO in the details provided in this Policy. We encourage you to use the latest version of web browsers for your own safety and security. Updated web browsers are normally equipped with security features that provide anti-phishing protection, improved parental controls, and tools to prevent malware and other privacy threats. We will not be liable for any damage, loss, injury, or claim that may result when you fail to comply with these obligations.

As provided under the Data Privacy Act of 2012, you have the following data privacy rights:

• Right to be informed
• Right to erasure or blocking
• Right to damages
• Right to file a complaint
• Right to rectification
• Right to data portability

You may contact our DPO in the details provided in this Policy whenever you want to exercise any of your rights as a data subject.

MINORS

SMIC shall not knowingly collect personal data of a person below the age of 18 years without any legal basis. Should it come to our attention that the personal data of minors was provided without a legal basis, such personal data shall be destroyed or deleted in a secure manner.

Minors are advised not to provide any personal data, such as their name, age, gender, email address, contact information, among others, and should consult their parent(s) or guardian(s).

CONTACT US

For inquiries regarding the processing of personal data, as well as any concerns or complaints regarding data privacy, or should you want to exercise your rights as a Data Subject, you may contact the DPO in the details below at:

The Data Protection Officer

10th Floor One E-Com Center
Ocean Drive, Mall of Asia Complex
CPB-1A, Pasay City 1300, Philippines
Tel: (632) 8857-0296
Email: dataprivacy@sminvestments.com

We encourage you to submit your inquiry and/or concerns in writing for proper documentation and tracking.

CHANGES IN THE PRIVACY POLICY

SMIC may change this Privacy Policy from time to time without prior notice. Revised versions of this Privacy Policy will be posted on this page, together with an updated effective date.

March 2022 version

Please click here to view our Seal of Registration from the National Privacy Commission (NPC).