GintoCash Technology OPC (GintoCash) respects our customers’ fundamental right to privacy, and we commit to taking great care in safeguarding your data. We have developed a Privacy Policy that aims to ensure that we adopt and observe appropriate standards for personal data protection in compliance with Republic Act No. 10173 or the Data Privacy Act of 2012 and its implementing rules and regulations. 

While our Privacy Policy sets out the general principles that govern the collection, use, and disclosure of our customers’ personal information, we have also developed this Privacy Commitment to inform you more specifically about our privacy practices. 

Why do we collect your personal information?

As an Account Holder of the GintoCash Portal, we collect and maintain some basic information about you. We do so only for the following purposes: 

• To create and nurture a relationship with you, so that we can continuously provide you with the various services and perks made available by the GintoCash Portal. For example, when you submit your application form to be a member/user, we collect personal information about you that will allow us to validate your identity and transaction history to determine if you are qualified to receive reward points and trade using the GintoCash Portal.
• To improve our GintoCash Portal. We collect, use, process, and analyze your trade and services-related activities so that we can understand how to improve our GintoCash Portal and services for your benefit.
• To understand your needs and preferences so that we can serve you better. Maintaining a record of the products and services that you avail in the GintoCash Portal allows us to gain a better insight into the kinds of offers that would be relevant to your preferences. We may send you product recommendations and special offers that we think will interest you.
• To continuously improve our business and operations. For example, we provide customer care activities, monitor the quality and security of the network, train our staff, and plan for future growth.
• To meet legal and regulatory requirements. We perform such other processing or disclosure that may be required to comply with pertinent laws, rules, or regulations.

Where do we get this information? 

There are several ways we collect information about you. 

Information that you give us. 

Most of the personal information we have are those that you have given us yourself. You provide us with personal information when you: 

• Apply for membership by filling out Application Forms, Subscription Agreements, and other similar or related documents through any of our available channels, including any similar forms you submit to your service providers (online, in our stores, or through our associates or representatives);
• Get in touch with us to ask about something or request for service.
• Take part in our research and surveys.

We also collect information as you avail of the services of the GintoCash Portal, like when you: 

• Use our facilities and services;
• Use our apps, websites, and self-service channels and portals.
• Join GintoCash activities

Information we collect from other sources 

We also collect personal information about you through other activities such as our market research initiatives, when you visit and transact in our stores when you visit and use our website, and from our subsidiaries, affiliates, and third-party business partners to whom you have given your consent for them to share your information with us. 

When we disclose personal information 

There are a variety of circumstances where we may need to share some of the information that you have provided to us. In these cases, we ensure that your personal information is disclosed on a confidential basis, through secure channels, and only in compliance with the Data Privacy Act. 

We will never share, rent, or sell your personal information to third parties outside of GintoCash Technology OPS, (GintoCash). Except in special circumstances where you may have given your specific consent for, and as described in this policy. 

In some instances, we may be required to disclose your personal information to our agents, subsidiaries, affiliates, business partners, and other third-party agencies and service providers as part of our regular business operations and for the provision of our products and services. This means we may share your information with: 

• Our service providers, contractors, and professional advisers help us provide our products and services. This includes partner companies, organizations, or agencies, and their sub-contractors.
• Our Subsidiaries and Affiliates with whom you have also signed-up with. We do so only for the improvement of each other’s business and operations.
• Other companies to whom you have also given consent for us to share your information; and
• Law enforcement and government agencies, but only when required by laws and regulations and other lawful orders and processes.

How we protect your personal information?

The integrity, confidentiality, and security of your information are important to us. That’s why we strictly enforce our Privacy Policy within GintoCash Technology OPC (GintoCash) and have implemented technical, organizational, and physical security measures that are designed to protect your hnformation from unauthorized or fraudulent access, alteration, disclosure, misuse, and other unlawful activities. These are also designed to protect your information from other natural and human dangers. 

We also put in effect the following safeguards: 

• We keep and protect your information using industry-standard security like firewalls, encryption, and security controls.
• We keep your information only for as long as necessary for us to (a) provide the products and services that you avail from us, (b) for our legitimate business purposes, (c) to comply with pertinent laws, and (d) for special cases that will require the exercise or defense of legal claims.
• We restrict access to your information only to qualified and authorized personnel who are trained to handle your information with strict confidentiality.
• We undergo regular audits, and rigorous testing of our infrastructure’s security protocols, which may include independent third-party audits and testing to ensure your data is always protected.
• We promptly notify you and the National Privacy Commission, when sensitive personal information that may, under the circumstances, be used to enable identity fraud is reasonably believed to have been acquired by an unauthorized person.
• We let you update your information securely to keep our records accurate.

We will not collect, use, or disclose your personal information for any purpose other than those identified in this Commitment, Terms of Service, and any other purpose that you may have given your consent for. 

What your choices are? 

You are afforded certain rights about your data under the Data Privacy Act. We would like to ensure that we have your consent to continue to collect, use, and disclose your personal information for the purposes that we have identified. At the same time, we want you to know that you do have choices and can object or withdraw your consent and/or edit your consent preferences at any time. 

If you wish to have access to your personal information in our records; or you think that such personal information we have of you is incomplete, not up-to-date, or otherwise inaccurate, you may get in touch with us at GintoCash Technology OPS (GintoCash). In some instances, we may request supporting documents or proof before we effect any requested changes to your personal information. 

What happens when there are changes in our Policy?

From time to time, we may update our privacy policy and practices to comply with changes in applicable laws, comply with government and regulatory requirements, adapt to new technologies and protocols, align with industry best practices, and for business purposes. 

You will always be provided notice either ​​through SMS, e-mail, the website, or the app if these changes are significant, and if we are required by law, we will ensure to obtain your updated consent. 

Your Consent(s) 

Throughout your use of our GintoCash Portal services, you agree and allow GintoCash Technology OPC (GintoCash) to use your personal information for the following purposes: 

1. 1. To create and nurture a relationship with you.

We collect personal information about you when you apply for our products and services so that we can validate your identity. We use your personal information to provide you with the best products, services, and benefits. 

2.                         Getting to know you better.

We also collect personal information about you through other activities such as our market research initiatives, when you visit and use our websites GintoCash Technology OPC (Ginto Cash), and from our subsidiaries, affiliates, and third-party business partners to whom you have given your consent for them to share your information with us.  

3.                         The improvement of our business and operations.

We analyze data about how you use our products and services to help us manage your account better, provide you with customer care activities, ensure your fair use of our products and services, monitor the quality and security of our technology, train our staff, and to plan for our future growth. We do this so that we can continue to provide you with the best experience for the products and services that you avail from us. 

4.                         The improvement of our products and services.

We analyze how you use our products and services so that we can understand how to improve them for your benefit. Our analysis may include some sensitive information about your usage, such as the general locations and sites that you may frequent. In all cases, we ensure to aggregate and anonymize this information so that you are never identified as an individual.  

* Aggregating simply means presenting information in segments or categories like age groups; anonymizing means removing information that can personally identify you from the data. 

5.                         Sending you product recommendations, special offers, and promos.

We will send you offers that we think will interest you. We keep a record of the products and services that you avail from us so that we can gain a better insight into the kinds of offers that would be relevant to you. We also analyze the places where you may have used our products and services and use this information to send you exclusive offers available in locations that you may frequent. You can choose to unsubscribe from these messages anytime. Just let us know. 

6.                         To interact with you on social media.

We place advertisements about our latest products and promotions on some of the most popular Websites, Social Media, and Search platforms. We may share information such as your mobile number, e-mail address, and cookies (from when you visit our websites) with the likes of Facebook and Google, to ensure that advertisements about our special offers are seen by you, as you browse their websites and apps. 

7.                         Compliance with other legal and regulatory requirements.

We perform other activities and disclose data in cases where we are required to do so for us to comply with government laws, rules, or regulations and with other legal processes and orders. 

There are some instances where we may need to share your information with our subsidiaries and affiliates, agents, business partners, and other third-party agencies and service providers. We only share your information to enable us to continue providing you with the products and services that you have availed from us and as part of our regular business operations that allow us to serve you better. 

The Data Privacy Act of 2012 (Republic Act No. 10173) gives you rights to the personal data that we have collected about you, including the right to object to certain ways in which we may use your data, the right to access your data at your request, the right to correct any inaccurate or outdated data about you, and the right to erase or remove your data from our records.