PRIVACY POLICY

Last Updated: January 9, 2023

This Privacy Statement outlines our policy in relation to the collection, use, and protection of your Personal Data, as defined below.  We reserve the right to update and amend our Privacy Policy to reflect current changes in our policy and the law. This Privacy Policy applies to all past, present and prospective Complex Philippines, Inc. customers. When we do so, we will notify you by posting it on our website for your information and reference.

​As part of our continuing relationship with you, we collect, process, use, and share your Personal Data with our subsidiaries, affiliates, partners, and third-party service providers as part of business operations and provision of products and services in accordance with this Terms of Use for the use of Complex PH products and services, as may be applicable.

1. CATEGORIES OF PERSONAL DATA WE COLLECT

The personal information that we collect, process, use, and share are either Personal Information or Non-Personal Information (collectively referred to as “Personal Data”):

1. Personal Information is any information from which the identity of an individual can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual, such as name, gender, date of birth, address, telephone/mobile number, email address, proof of identification, etc. It may also include location of your device whenever it is switched on, if you subscribe to and consent to using location-based services.

2. Sensitive personal information refers to personal information:

a. About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;

b. About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;

c. Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and

d. Specifically established by an executive order or an act of Congress to be kept classified.

We do not collect, and process Sensitive Personal Information without obtaining your consent.

The following Personal Data are collected automatically via Google Analytics:
1. Cookie Data
2. Age
3. Interests
4. Device
5. Location

We collect the following upon successfully registering through the Subscription Form:
1. Email address

2. PURPOSES FOR COLLECTING AND PROCESSING PERSONAL DATA

Personal Data is collected and processed for the following purposes:

1. Provide you with your availed products and services, including customer support;
2. Enhance your customer experience and determine tailored content to meet your preferences and needs;
3. Communicate relevant services and/or advisories to you;
4. Abide by any safety, security, public service or legal requirements and processes;
5. Comply with the requirements of the law and legal process, such as a court order; to comply with a legal obligation; or to prevent imminent harm to public security, safety, or order, collectively referred to as “Data Use Purpose.”

3. SECONDARY PURPOSE/S

We will not disclose your personal data for any secondary purposes unless your consent has been previously obtained in accordance with law.

4. DISCLOSURE OF PERSONAL DATA

We may outsource or contract the processing of Personal Data to third parties, such as but not limited to, vendors, service providers, partners, or other telecommunications operators, to fulfill any of the above purposes. They are only authorized to use Personal Data for such contracted purposes. We require them to protect Personal Data consistent with our Privacy Policy.

5. DATA SUBJECT RIGHTS

​Complex Philippines, Inc. (“Complex PH”) recognizes that you should be the ultimate decision-maker on matters that involve your Personal Information. To this end, Complex PH is mindful of the fundamental right to privacy of every Complex Philippines, Inc. customer under the Data Privacy Act of 2012, and its Implementing Rules and Regulations (“DPA”).

By accepting the Terms of Use below, you agree to the collection, processing, use, and sharing of your Personal Information in accordance with this Privacy Statement that will enable us to provide you with your desired Complex PH products and services. Unless specifically provided, the defined terms here shall have the same meaning ascribed to them in the DPA.

As the Data Subject, you have the following rights:

1. You have the right to be informed of the Personal Information that we collect, process, use, and share about you. When you request it, we can provide you an overview of your personal data that we process, provided that such Personal Information does not amount to information deemed confidential or proprietary by Complex PH, or that your request for Personal Information is not vexatious or unreasonable.

2. You have the right to object or withhold your consent to the collection, processing, use, and sharing of your Personal Information. However, we may be constrained to terminate your Complex PH product or service as your Personal Information will be required to deliver such Complex PH. product or service. Without your Personal Information, we will be unable to provide you with updates on Complex PH’s latest offerings; similarly, you will be unable to participate in our events, promotions, or other activities.

3. You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your Personal Information in our processing systems upon discovery and substantial proof that your Personal Information is no longer necessary for the purpose or purposes for which it was collected, and for such other cases provided in the DPA.

4. You have the right to seek indemnity for damages sustained, if any, due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your Personal Information.

6. RETENTION OF PERSONAL DATA

We will retain your personal information only for as long as necessary to provide our services, to fulfill the purposes listed above, and to comply with legal requirements.

When your personal information is no longer necessary for compliance with legal obligations, it shall be removed and deleted from our storage facilities including all copies made.

7. SECURITY

We secure and protect your Personal Data with proper safeguards to ensure that it is kept confidential and private. We make reasonable and appropriate security arrangements to comply with legal requirements and to prevent its loss, theft, or use for unauthorized purposes.

8. CONTACT US

Should you feel that there has been mishandling or misuse of your Personal Information, that any of your data privacy rights have been violated, or if you would like to object to the collection and processing of your Personal Information, you may email us at [email protected].

(c) 2022, Complex Philippines, Inc. ALL RIGHTS RESERVED.