Last Updated: November 25, 2021
We may obtain information about you in a variety of ways, including through your use of our website(s) & services referred therein (Services), when you call, email or otherwise communicate with us (including through social media), or when you participate in events or other promotions organized by 24 Pilipinas or in collaboration with any third party.
This includes information provided by you directly to us or collected by your use of our Services. We may obtain information about you (including personal information) from our business partners, such as vendors, and other third parties.
You may choose not to provide some or all of your personal information to us but doing so may prevent us from providing our Services to you or limit our ability to provide you with the level of service that you would otherwise expect from us.
Information collected from you
The following are examples of the types of information we may collect directly from you:
Feedback: From time to time, we may request your opinions, suggestions, or modification and improvement ideas ("Feedback") through surveys, or other similar requests. Any responses you provide are voluntary, however you agree that any Feedback you provide shall be owned by 24 Pilipinas and may be used by 24 Pilipinas in its sole discretion.
Syncing Cookies and Identifiers: We may work with our partners (for instance, third party ad platforms) to synchronize unique, anonymous identifiers (such as those associated with cookies) in order to match our partners' uniquely coded user identifiers to our own. We may do this, for instance, to enhance data points about a particular unique browser or device, and thus enable us or others to send ads that are more relevant, match Users to their likely product interests, or better synchronize, cap, or optimize advertising.
Locally Stored Objects: Our network Services may employ locally stored objects ("LSOs") and other client side storage tracking technologies in certain situations where they help to provide a better user experience, such as to remember settings, preferences and usage similar to browser cookies, or in order to target or help our partners target ads, analyze ad performance, or perform user, website or market analytics. For LSOs utilized by Adobe Flash you can access flash management tools from Adobe's website. In addition, some, but not all browsers, provide the ability to remove LSOs, sometimes within cookie and privacy settings.
We may work with certain third-party companies that use techniques other than HTTP cookies to recognize your computer or device and/or to collect and record information about your web surfing activity, including those integrated with our Services. Please keep in mind that your web browser may not permit you to block the use of these techniques, and those browser settings that block conventional cookies may have no effect on such techniques. To learn more about Interest-Based Advertising or to opt- out of this type of advertising by those third parties that are members of DAA's opt-out program, please go to http://www.aboutads.info.
Web Beacons: We and our partners may also use "web beacons" or clear GIFs, or similar technologies, which are small pieces of code placed on a Service or in an email, to monitor the behavior and collect data about the visitors viewing a Service or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that Service. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).
Mobile Device Identifiers and SDKs: We also sometimes use, or partner with publishers, publisher-facing, or app developer platforms that use mobile Software Development Kits ("SDKs"), or use an SDK with a mobile app that we offer, to collect Information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), and Information connected to how mobile devices interact with our Services and those using our Services. A mobile SDK is the mobile app version of a web beacon (see "Web Beacons" above). The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services or analytics to be performed. We may use this technology to deliver or help our Partners deliver certain advertising through mobile applications and browsers based on information associated with your mobile device. If you'd like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions in the "Your Ad Choices" section below.
By visiting the Service, whether as a registered user or otherwise, you acknowledge, and agree that you are giving us your consent to track your activities and your use of the Service through the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send to you.
Our unaffiliated partners and third parties may themselves set and access their own tracking technologies when you visit our Services and they may have access to information about you and your online activities over time and across different websites or applications when you use the Service. Their use of such tracking technologies is not in our control and is subject to their own privacy policies.
In addition to cookies, other technologies that may be used us include:
- "Pixel tags" (also known as a "clear GIFs" or "web beacons") which are tiny images (in most cases, typically just one-pixel) that can be placed on a web page or in our electronic communications to you in order to help us measure the effectiveness of our content, for example, by counting the number of individuals who visit us online or verifying whether you've opened one of our e-mails or seen one of our web pages.
- "HTML5" (the language some websites, such as mobile websites, are coded in) may be used to store information on your computer or device about your website usage activities and to help determine how our Services are being used by our visitors, how the services can be improved and to customize our Services for our users.
Automated Information includes information such as:
- IP address
- Operating system used (for example: iOS, Android)
- Internal resolution of the browser window
- Device type
- Country code
- Identifiers associated with technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address)
- Dates and times of access
- IDFA (Identifier for Advertisers)
- Subscription information
This Automated Information is generally used for the following purposes:
- for the technical provision of our Services in order to be able to provide you with a functioning user-friendly experience;
- to provide you with a secure experience and to take measures to protect our website and mobile applications from cyber risks;
- to uncover insights about your use of our website and mobile applications in order to improve our Services and features, including developing new products and features;
- to facilitate your access to our website or mobile application;
- to customize our Services for you;
- to help us better understand our current and potential customers so that we may market our Services accordingly;
- events and usage data are captured for our internal business analytics in order to understand how our users interact with our mobile applications and use our services. For example, we may capture when a user visits a screen, taps a button, permits notifications, upgrades, or otherwise interacts with the app; and
- Monitoring and analyzing the effectiveness of our communications (including by identifying when emails sent to you have been received and read).
We may obtain information, including personal information from third parties and sources that we integrate into our Services either for the provision of our services or to facilitate your access to our Services such as described below.
In addition to the purposes described above, we may use the information we collect for a variety of purposes, such as the following:
Performing Our Services
- Maintaining or servicing accounts, providing customer service, operation our website and mobile applications; processing or fulfilling orders and transactions, verifying user information, processing payments.
- Communicating about the products and Services we offer, and responding to requests, inquiries, comments, and suggestions.
- Understanding and evaluating how our Services and features perform with our users.
- Uncovering insights about usage in order to improve the Services and provide customers with enhanced features as well as inform our development of new features and products.
- Development of customized or personalized experiences of our Services, such as remembering your information so you do not have to re-enter it each time you use one of our Services.
Auditing Interactions with Consumers
- measuring usage of our websites and mobile applications.
- measuring our advertising and marketing activity (e.g., measuring how a user was acquired).
- To provide you with a secure experience and to take measures to protect our website and mobile applications from cyber risks.
- Protecting against, identifying, investigating, preventing, and responding to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern the Services we provide.
- identification and repair of impairments to intended, existing functionality of our Services.
- Understanding our customer in order to more effectively provide our Services.
Quality and Safety Maintenance and Verification
- activities related to improving the quality of the Services we provide, including upgrade or enhancement of the Services
- verification or maintenance of the quality or safety of Services
- Tracking and responding to quality and safety matters
- Protecting our rights and property
- Complying with legal or regulatory requirements, judicial process, industry standards and 24 Pilipinas's policies.
- Other purposes that may be described at the time you choose to provide personal information to us.
To perform the above functions, we may match information collected from you through different means or at different times, including both personal information and Automated Information, and use such information along with information obtained from other sources. We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.
We share your information within of 24 Pilipinas for legitimate business purposes, including:
- to assist us in technical processing operations, such as data hosting and maintenance, finance, legal, HR and accounting assistance, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings; and
- for corporate audit, analysis and consolidated reporting as well as compliance with applicable laws.
We may share information about you with the following categories of third-party providers for a variety of business purposes:
- Customer Communications and Insights Platforms: We may share your phone number, email, app usage and interactions with our third-party customer communications platform providers for the following business purposes: performing services that allow us to communicate with you and administer your account as well as track your usage for our internal analytics.
- Internal Business Insights Platforms: Our third-party internal business analytics platform provides us with the tools to help us understand app usage and interactions and uncover insights that allow us to improve our product and features. We may share or make available unique user identifiers, IDFA, device ID, IP address and app usage and events (such as when you subscribed to our services) with these providers for the following business purposes: performing services that allow us to (i) monitor and understand usage in order to enhance existing Services or develop new products and features and (ii) better understand our customers in order to market our products more effectively.
- Measurement and Attribution: The service providers offer tools that allow us to measure and attribute the source of new subscription sign ups and that allow us to uncover insights about usage and app events. We may use unique user identifiers made available to us from these third-party providers to help us measure the effectiveness of our ads (e.g., where and how a user is acquired) and to uncover information about how our customers are using our apps in order to improve their quality and safety. We may also share and/or store unique user identifiers, device IDs, IDFA or IP addresses with these providers for the same purpose.
- Other technology providers: These are necessary to provide our services (including cloud storage and web hosting providers). We may use certain Automated Information and/or aggregate or non-personally identifiable information available with us from customer/ third parties for various purposes including monitoring network traffic to detect malicious actors and to protect against malware, fraud or other unlawful uses or activity.
Legal, Regulatory, Compliance and Similar reasons.
In addition, we may disclose and/or share your information to comply with legal or regulatory requirements (including to comply with a court order, judicial subpoena or other subpoena or warrant), industry standards, judicial process, and our company policies, as well as to protect against, identify, investigate, prevent and respond to fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), adverse event reporting, and claims and other liabilities.
We also reserve the right to disclose your information (i) when we believe in good faith that disclosure is appropriate or necessary to take precautions against liability, (ii) to protect our rights or property or the legal and property rights of others and (iii) investigate and defend third party claims or allegations against us.
5. Do Not Track Disclosures
Some web browsers may transmit "do-not-track" signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Since there is no industry standard concerning what websites should do when they receive such signals, our websites do not currently process or respond to "do-not-track" (DNT) settings in your web browser. If and when a final standard is established and accepted, we will reassess how to respond to these signals.
Certain third parties, such as ad networks, web analytics companies and social media and networking platforms, collect information about your online activities over time and across websites. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. Information about how to opt out from your data being used by third parties can be found under clause 2 "Information collected by automated means"
6. Social Media and Other Communications
If you choose to communicate with us or another user through social features available on our websites or mobile applications or through our social media pages, or other similar communication or messaging features or services, such information may be made publicly available. For security purposes, please do not include any password, social security number, card or other sensitive information via these features. We have the right, but not the obligation to monitor messages and communications between and among users for security and training purposes. We may, but are not obligated to, remove any content we deem inappropriate.
7. Your rights for the personal data we hold about you
For your protection, we may require proof of identity and verification before we can answer the above requests.
Legal basis for processing data
In this section, we have set out the legal grounds on which we rely to process personal information.
In some cases, we have a legitimate interest to process the personal information that we collect, such as to develop, administer and support our products and services; to operate, evaluate and improve our business; to facilitate and manage engagement programs; to promote research; to support our recruitment activities; or to facilitate a Corporate Transaction (including a sale of assets or merger or acquisition).
In other cases, we process personal information to fulfill our contracts with business partners, such as third parties that distribute our products.
It may also be necessary for us to process personal information to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide.
Our processing of certain information may be necessary to comply with our legal obligations, and for reasons of public interest, such as with respect to adverse event and product safety reporting.
We may also process personal information as specifically permitted by applicable legal requirements.
If we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information.
International data transfers
8. Online Privacy Choices and Rights
Access, Edit and Delete Your Information.
Mobile platforms have permission systems for specific types of device data and notifications, such as camera and microphone as well as push notifications. Where applicable, you can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
You can stop all information collection by the app by disabling call forwarding and deactivating your account by following the instructions on the Service's Settings screen and then uninstalling the app using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
If you choose to opt-in, some of our apps may collect your device's precise real-time location, and in such cases, you may be able to opt out from further allowing us to have access to such location data by managing your location preferences in the app and/or on your device.
You may choose whether to receive some interest-based advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance's ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising, including use of cross-device data for serving ads, visit http://www.aboutads.info for information on the DAA's opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected members no longer deliver certain interest-based advertising to you but that does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, using a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective.
10. How We Protect Personal Information
We apply various measures from time to time to safeguard the security and integrity of your personal information collected through our Services. Despite these measures, however, we cannot and do not guarantee that information will be absolutely safe from interception or intrusion during transmission or while stored on our system, or otherwise, and you provide information to us at your own risk.
If you correspond with us by email, text message or using web forms like a "contact us" feature available through our Services, you should be aware that your transmission might not be secure from access by unauthorized parties. We have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission. If you create an account as part of using our Services, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. Please notify us of any unauthorized use of your password or account.
If we believe that the security of your personal information in our care may have been compromised, we may seek to notify you but are not obliged to do so. If we have your email address, we may notify you by email to the most recent email address you have provided us in your account profile but are not obliged to do so. Please keep your email address in your account up to date. You can change that email address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your email account using your computer or mobile device and email application software. We may also post a conspicuous notice on our site or notify you through the mobile application. You consent to our use of email, text message and/or notification through the app as a means of such notification. If you prefer for us to use the postal service to notify you in this situation, please let us know by submitting your request here. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this email address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your personal information.
11. Links to Websites and Third-Party Content
For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of any third party entity. We encourage you to review the privacy policies of such third parties before providing them with any personal information. Please refer some of such third party’s information in Apendix-1
12. Information Relating to Children
14. How to Contact Us
You may contact us with questions, comments, or concerns about our Services :