ADWAYS PHILIPPINES INC.

PRIVACY POLICY

This policy laid out the commitment of Adways Philippines Inc. (“Adways”) the handling of personal information and sensitive personal information collected in accordance with the rules and regulations set out on Republic Act 10173, also known as Data Privacy Act of 2012 – An Act Protecting Individual Personal Information in Information and Communications System in the Government and Private Sector, creating for this purpose A National Privacy Commission And For Other Purposes – which took effect on September 08, 2012.

We will establish a system, establish the following privacy policy, and declare that we will implement and maintain it.

Personal information of our customers, business associates, partners, etc. that we use in our business, in compliance with laws and regulations regarding the protection of personal information, and we will also consider international guidelines and principles, consent and agreement. In order to carry out this declaration, we have established the "Personal Information Protection Regulations" and made it known to our employees (including all officers and employees, part-time workers, temporary workers, etc.) and other related parties.

We will take appropriate information security measures such as measures against unauthorized access and computer viruses to prevent loss, destruction, falsification and leakage of personal information.

We will acquire personal information by legal and fair means, and will not acquire it by improper methods. In addition, data are collected for specified and legitimate purposes determined and declared before, or as soon as reasonably practicable after collection, and later processed in a way compatible with such declared, specified and legitimate purposes only.

When we obtain personal information from a third party provider, we will check whether the personal information we obtain is properly obtained by the provider. We will confirm that the person has the right to disclose, modify, suspend the use, delete, etc. of his/her personal information, and will respond appropriately to these requests from the person.

When sharing personal information with a third party or when entrusting personal information to a third party to outsource business, we will investigate the third party and conclude necessary contracts, etc. We will take necessary measures by law.

Established on February 8, 2008

Revised on December 25, 2017

ADWAYS PHILIPPINES INC.
Representative Director Yuichi Sakagawa

Handling of personal information

1.Acquisition of personal information

We will collect personal information of the person in order to provide the service operated by the company and to the extent necessary for the operation of the service. We will properly acquire personal information and will not acquire personal information by deception or other improper means. When we receive personal information from the person, we will clearly indicate to the person that we will acquire it, notify or announce it. In addition, we will not acquire, use or provide personal information including the following contents:

  1. Matters concerning ideas, beliefs and religions;
  2. Race, ethnicity, family origin, registered domicile (excluding information about the prefecture where you are located), physical/mental disorders, criminal history, and other matters that cause social discrimination;
  3. Matters concerning workers' right to organize, collective bargaining and other acts of collective action;
  4. Matters concerning participation in collective demonstrations, exercise of right to petition and exercise of other political rights;
  5. Matters concerning health care and sexual orientation and preferences

2.Use and handling of personal information

The acquired personal information of the person shall be used only by those who are authorized according to the specific business within the scope of the purpose of use described below, as long as it is necessary for the performance of the business.

We handle personal information with the care of a good manager in accordance with the Republic Act 10173 also known as "Act on the Protection of Personal Information" (hereinafter referred to as the "Data Privacy Act on the Protection of Personal Information").

Purpose of use
① Personnel recruitment activities (document screening, contacting applicants, etc.);
② Security management of our company's crime prevention and disaster prevention, etc.;
③ Preparation of tax documents such as withholding taxes and payment records;
④ Preparation of documents related to various social insurance such as health insurance, welfare and management of various social insurance;
⑤ Management of personnel and labor, welfare, etc.;
⑥ Billing and payment for various transactions;
⑦ Dividend payment;
⑧ Transaction examination, credit examination, report and contact of the examination result, etc.;
⑨ Use of contacts regarding business visits (including business negotiations);
⑩ Response to inquiries (email, phone, etc.);
⑪ Identity verification (including age verification) and order confirmation;
⑫ Sending mail, products, etc.;
⑬ Various information and contact regarding products and services;
⑭ Various information and contact regarding campaigns, events, questionnaires, seminars, etc.;
⑮ Password issuance;
⑯ Delivery of e-mail newsletter;
⑰ Contact when introducing or using each service;
⑱ Contact in case of violation of terms, contract or law;
⑲ Login authentication for each service;
⑳ Distribution and sales of each service;

3.Definition of personal information;

We refer to personal information as information about living individuals (name, address, and other information that can identify a specific individual and information that includes a personal identification code) as stipulated in the Personal Information Protection Law. Information such as e-mail address, access record, user ID, password, credit card used together with an individual, preference information integrated with personal information, family structure, date of birth and other attribute information about an individual.

4.Information that cannot identify a specific individual, etc.

For other information that cannot identify a specific individual, such as cookie/IP address information, mobile identification number (individual identification number), identifier for advertisement distribution, and behavior history information, the information alone identifies a specific individual. We do not recognize those as personal information. However, if the information is used together with personal information, the information will also be regarded as personal information because it can identify a specific individual.

In the services provided by our company, even if it is not possible to identify a specific individual, other identification such as cookie/IP address information, mobile identification number (individual identification number), identifier for advertisement distribution, behavior history information, we will disclose the purpose of use as it is.

In addition, we provide information that cannot identify a specific individual, such as cookie / IP address information, mobile identification number (individual identification number), identifier for advertisement distribution, and behavior history information, to affiliated companies such as subsidiaries. We may share it with the affiliated company and use it with the affiliated company within the scope of the purpose of use described below:

Purpose of use
① Report of advertising effectiveness measurement results to advertisers;
② Report for improving the judgment of advertising placement on advertising media;
③ Notification on advertisement placement regarding each service such as SSP;
④ Verification / improvement of advertising results;
⑤ Improvement of each service, improvement of convenience;
⑥ Customer classification, customer analysis, survey of consumer trends;
⑦ Optimal advertisement distribution and service function provision;
⑧ Use as marketing information such as analysis / editing / processing as statistical information and reporting to other companies;

5.Notification, publication and change of purpose of use of personal information;

When we acquire and handle personal information of the person, we will specify the purpose of use as much as possible, clarify the purpose of use to the person in advance, or notify or announce it. In addition, when changing the purpose of use of personal information, we will not do so beyond the range reasonably recognized as having relevance to the purpose of use before the change, and the person himself/herself regarding the changed purpose of use. We will notify or publish it. However, this does not apply in the following cases:

  1. When there is a risk of harming the life, body, property or other rights and interests of the person or a third party by notifying or disclosing the purpose of use to the person;
  2. When there is a risk of harming our rights or legitimate interests by notifying or disclosing the purpose of use to the person;
  3. When it is necessary for a national institution or a local public to cooperate in carrying out the affairs stipulated by laws and regulations, notifying the person of the purpose of use or making it public will hinder the performance of the affairs and when there is a risk of exerting it;
  4. When it is recognized that the purpose of use is clear from the status of acquisition;

6.Scope of use of personal information

We will not handle personal information beyond the scope necessary to achieve the purpose of use without obtaining the consent of the person.
However, this does not apply in the following cases:

  1. When required by law;
  2. When it is necessary to protect the life, body, or property of the person or a third party, and it is difficult to obtain the consent of the person;
  3. When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the individual;
  4. When it is necessary for a national institution or a local public body or a person entrusted with it to cooperate in carrying out the affairs stipulated by laws and regulations, obtaining the consent of the person will hinder the performance of the affairs and when there is a risk;
  5. When handling within the range where an individual cannot be identified.

7.Provision of personal information

In principle, we will not provide your personal information to a third party without your consent.
However, in the following cases, the Company shall be able to provide the personal information of the person to a third party:

  • With the consent of the person;
  • When required by law;
  • When it is necessary to protect the life, body, or property of the person or a third party, and it is difficult to obtain the consent of the person;
  • When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the individual;
  • When it is necessary for a national institution or a local public body or a person entrusted with it to cooperate in carrying out the affairs stipulated by laws and regulations, obtaining the consent of the person will hinder the performance of the affairs and when there is a risk;
  • When a court, public prosecutor's office, police, tax office, bar association, or an organization with similar authority requests disclosure of personal information;
  • When outsourcing all or part of the business performed by the Company to a third party to the extent necessary to achieve the purpose of use;
  • When disclosing to persons who have a duty of confidentiality to the Company, such as lawyers/accountants, due to the necessity of our business;
  • When giving out information of individuals who use paid services to payment system companies and credit companies that are outsourced to our business (conclude nondisclosure agreements) for the purpose of charging usage fees to those who use paid services;
  • When disclosing the personal information of the person who participates in the seminar to the company co-sponsoring the seminar;
  • When necessary to exercise our rights;
  • When statistically processed so that no individual can be identified;
  • When disclosing to the person who succeeds the business at the time of business succession due to merger, business transfer or other reasons;
  • When the following matters are notified or announced without the prior consent of the person:
    • Include the provision of personal data to a third party in the purpose of use;
    • Items of personal data provided to third parties and methods of provision;
    • Suspending the provision of personal data that identifies the individual to a third party at the request of the individual;
    • How to accept your request

8.Outsourced supervision

We will provide necessary and appropriate supervision when we outsource all or part of the handling of personal information, we will conclude a contract including confidentiality with the outsourcer or request agreement on the terms and conditions established by the outsourcer, and the outsourcee will manage the safety of personal information.

9.Disclosure / correction / addition / deletion / suspension of use / suspension / deletion of personal information

If you wish to disclose, correct, add, delete, suspend the use, suspend the provision, delete, etc. of your personal information, we will confirm your identity and the authenticity of the information according to the procedures prescribed by our company. We will promptly take measures such as disclosure, correction, addition, deletion, suspension of use, and suspension of provision and deletion of personal information provided by the person. However, if any of the following items apply, we may not be able to respond to disclosure, correction, addition, deletion, suspension of use, suspension of provision, deletion, etc. In that case, we will notify the person and explain the reason.

  1. When there is a risk of harming the life, body, property or other rights and interests of the person or a third party;
  2. When there is a risk of significant hindrance to the proper implementation of our business;
  3. When it violates the law;
  4. When the person requests correction, addition or deletion of personal information because the content of personal information is different from the fact, and as a result of authenticity confirmation, the content of the personal information is true;
  5. When special procedures are stipulated by the provisions of other laws and regulations;
  6. When the person requests the suspension or deletion of personal information, the personal information is handled within the scope of the purpose of use. And if it does not correspond to illegal acquisition;
  7. When it costs a lot of money to suspend or delete personal information, or when it is difficult to suspend or delete other personal information, and it is a necessary alternative to protect the rights and interests of the person;
  8. When the person requests to stop providing personal information and the provision of personal information does not violate the provisions of Data Privacy Act;
  9. If it costs a lot of money to suspend the provision of personal information, or if it is difficult to suspend the provision to other third parties, and if necessary alternative measures are taken to protect the rights and interests of the individual;

If you wish to disclose, correct, add, delete, suspend the use, suspend the provision, delete, etc. of your personal information, please contact us at the contact information.

10.Voluntary provision of personal information

Whether or not you provide personal information to us is at your discretion. If you provide personal information to us, we will consider that you have licensed/authorized us to use your personal information in accordance with our privacy policy. However, if you do not provide the necessary items, you may not be able to receive each service provided by our company in an appropriate condition. In addition, cookie information can be rejected by the settings in your browser according to your preference. You may refuse cookies, however, you may not be able to receive each service provided by our company; this is a condition that would be made clear to the user.

11.About links

Our website contains links to some external sites, but does not share personal information. We are not responsible for the collection of personal information on the linked websites, so made sure to refer to the privacy policy of the linked websites.

12.About Security

The website operated by our company is managed by the use of special encrypted communication technology called SSL and a dedicated server protected by a security system called Firewall when registering the important personal information of the person, and unauthorized access from the outside. We are doing our best to prevent information leakage.

13.Privacy Policy Updates

When we update our privacy policy, we will post the update on this website. By posting the latest privacy policy on our site, we will always know how to collect and use personal information. Please check back regularly.

14.Contact

We have set up the following dedicated contact point for inquiries regarding disclosure, correction, addition, suspension of use, suspension of provision, deletion, etc. of personal information, and other opinions and requests regarding the handling of personal information, and are appropriate and prompt. I will try to respond.

● Dedicated window ●
Unit 602 Gagfa IT Center, F.Cabahug Street, Kasambagan, mabolo, Cebu City, 6000 Philippines
ADWAYS PHILIPPINES INC. Compliance Office
Personal information inquiry window : sakagawa.yuichi@adways.net
* Please note that we do not accept any requests or inquiries from customers who come directly to our office.

* Request to the person

  • On our website, your registration information may be protected by your ID and password. You are responsible for managing your ID and password.
  • In order to use each service provided by our company and the website operated by our company safely, please do not unnecessarily post personal information of other people or yourself on the website operated by our company.