AIR21 Global, Inc.

Data Privacy Notice

Effective Date: 17 September 2018

Last Updated Date: 17 September 2018

Table of Contents

This Data Privacy Notice sets out as follows:

  1. Scope and Acceptance
  2. Purposes of Collection
  3. Governance Guidelines
    1. Collection of Personal Information
    2. Sharing of Personal Information by ProbinsyaMart
    3. Storage of Personal Information
    4. Retention of Personal Information
  4. Information Security
  5. Your Rights
  6. Use and Definition of Session Data
  7. Contact Us

Scope and Acceptance

AIR21 Global, Inc. (“ProbinsyaMart”) complies with the Data Privacy Act of 2012 and is committed to protecting your privacy. ProbinsyaMart understands, accepts, and supports the need for reasonable protection regarding the privacy of personal information collected by ProbinsyaMart through client relationships and services and, thus, has developed and adopted general governance guidelines to comprise this Data Privacy Notice (“Data Privacy Notice”).

This Data Privacy Notice applies to and governs data collection, recording, updating, modifying or correcting, usage, sharing, storage, retention, destruction, or disposition by ProbinsyaMart in the websites and applications owned and/or operated by ProbinsyaMart. Your use of and our applications constitutes your agreement to this Data Privacy Notice.

When you interact with us, you may share personal information with us which allows identification of you as an individual (e.g. name, email, address, telephone number). This is known as “personal information.” This Data Privacy Notice provides a detailed overview of the practices of ProbinsyaMart, along with its affiliates and associates, with regard to how the personal information will be handled in compliance and in accordance with the Data Privacy Act of 2012, its implementing rules and regulations, and all other relevant data privacy laws.

This policy applies to all personal information that is collected, maintained, or used by ProbinsyaMart as part of their operations and marketing strategies. ProbinsyaMart reserves the right to amend this policy from time to time, should it become necessary to do so, with or without prior notice.

Purposes of Collection

The purposes for which ProbinsyaMart collects and uses personal information are the following:

  1. To provide access to our services. This includes, but is not limited to, the different systems that you use and which are primarily accessed through our official website,
  2. For marketing purposes. ProbinsyaMart may use your personal information to inform you of products and services that are being offered. You may be contacted for any and all purposes specified below:
    1. To market, promote, and advertise our products, services, events, initiatives, and activities;
    2. To customize our advertising, promotional, and marketing activities;
    3. To conduct research, surveys (participation is optional), and perform statistical analyses of user behavior with the aim of measuring relative consumer interest in our various products, services, and activities; and
    4. To promote and manage our customer rewards program(s).
  3. To generate analytics and perform analyses on consumer behavior. ProbinsyaMart may also use personal information to create aggregated data which will be used and shared with our affiliates and associates for research, analysis, and evaluation as ProbinsyaMart aims to improve our performance and delivery of services. ProbinsyaMart will make reasonable efforts to remove or obscure your personal information when presenting research, analysis, and evaluation reports.

Governance Guidelines

Collection of Personal Information

To access and/or use ProbinsyaMart applications, in the creation, registration, or maintenance of a user account specific to you, ProbinsyaMart may ask you to provide certain contact and personal information, such as your name, e-mail, home, work or some other address, telephone numbers (landline or mobile).

ProbinsyaMart may also collect additional information as required for processing of registration. Personal information may be collected or accessed in a number of ways, including:

  1. Receiving personal information directly from the client (whether in writing or verbally);
  2. Personal information generated by ProbinsyaMart from conversations, correspondence, appraisals, etc.; and
  3. Receiving personal information by affiliates and associates so that such affiliates and associates may administer the required services from ProbinsyaMart or provide other services on behalf of ProbinsyaMart.

ProbinsyaMart believes that, in most cases, the client is the best source of information about themselves. Therefore, to the extent that is practical and appropriate, ProbinsyaMart collects information personally from the clients. In those cases, in which it is necessary to collect personal information from other parties, ProbinsyaMart ensures the use of reputable sources and take measures to ensure that privacy interests are respected.

Sharing of Personal Information by ProbinsyaMart

Pursuant to the Data Privacy Act of 2012, ProbinsyaMart guarantees your personal information will only be accessed by authorized personnel and managed securely under appropriate online security measures to protect your personal information against loss or destruction. ProbinsyaMart further guarantees that your personal information will not be disclosed to unauthorized third parties.

ProbinsyaMart may share your personal information to authorized third parties, but only for the following circumstances:

  1. To send cross-promotions on behalf of their affiliates and associates. ProbinsyaMart may, from time to time, contact you on behalf of its affiliates about particular offers and/or services that may be of interest to you. In these cases, your unique personal information is not transferred to the affiliate.

Storage of Personal Information

ProbinsyaMart keeps personal information stored in the corporate databases and systems which are located in its principal office in 3F Cargohaus Building, Barangay Vitalez, NAIA Complex, Parañaque City, Philippines 1700, in corporate subscribed cloud storage, and data storage facilities such as servers that are located in the Philippines. These databases are controlled and can be accessed electronically only by select ProbinsyaMart administrative staff or duly authorized Trusted Contractors.

Retention of Personal Information

Personal information shall be kept in active files or systems only as long as needed to meet the purposes or business needs for which it was collected or as required by contractual agreement, by the Data Privacy Act of 2012 or other regulations, or, where applicable, for the appropriate statute of limitations period. Other considerations for retention of data will be in accordance to the SLU (scheduled loss of use) between ProbinsyaMart and the government agencies serviced by ProbinsyaMart.

Thereafter, your personal information may be anonymized or destroyed. When anonymized for research or statistical purposes, your personal information can and will no longer be associated with you, in which case ProbinsyaMart may use this information indefinitely without further notice to you. ProbinsyaMart may, at all times review, retain, and disclose any other information as ProbinsyaMart deems necessary to satisfy any applicable law, regulation, legal process, or governmental request. By doing so, ProbinsyaMart does not either express or imply, affirm, or, in any manner, assume any responsibility for such communications.

Information Security

ProbinsyaMart implements reasonable and appropriate organizational, physical, and technical security measures to protect any data, such as personal information, meta-data, or otherwise, that ProbinsyaMart collects from you. These security measures aim to maintain the confidentiality, integrity and availability of your personal information against any accidental or unlawful destruction, alteration, and disclosure, as well as against any other unlawful processing. ProbinsyaMart uses commercially reasonable methods, technology and tools to secure your personal information from unauthorized access, use or disclosure.

ProbinsyaMart secures the personally identifiable information you provide in the website and our applications in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information is transmitted to other websites or applications, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

ProbinsyaMart also has stringent protocols, policies and procedure for the collection, processing, and storage of personal information, including but not limited to ensuring that office spaces and work station shall provide privacy to anyone processing your personal information, encrypting your personal information during storage and, while in process, restricted access protocols, authentication procedures and regular scanning, testing and upgrading of its security measures against data breaches.

Your Rights

In accordance with the Data Privacy Act of 2012, you have the right to access, correct, and object to the processing of your personal information subject to exceptions allowed by the law. This also includes the right to lodge a complaint with the National Privacy Commission should you deem it necessary to do so.

You have the right to request access to your personal information. You may direct requests for access [email protected] In addition, you also have the right to correct any inaccuracies in your personal information. You may direct your concerns for rectification of erroneous details to [email protected]

Use and Definition of Session Data

ProbinsyaMart applications use Sessions to store information based on certain actions done or buttons that are clicked. The Session is kept only while the browser is open. When a browser is closed or if a certain length of time without activity in the browser has passed, the data is automatically destroyed or deleted. This ensures that the data can no longer be accessed or used in harmful ways. Refreshing the page or going to a different subpage of the same domain will not erase the data. Sessions are more secure than cookies as it is stored in the server. ProbinsyaMart uses Sessions to enable certain functions of our services and provide easier access to our applications.

Contact Us

ProbinsyaMart has a designated Data Protection Officer for the personal information it processes in the framework of this Data Privacy Notice. If you have questions or comments regarding this Data Privacy Notice, our data protection policies and practices, or the information that ProbinsyaMart holds about you, please contact us through [email protected]

We at ProbinsyaMart take your privacy seriously. We only use cookies to improve your experience with us. Take a look at our data privacy policy to know more about our commitment to you.