Privacy Policy

INTRODUCTION

First Balfour, Inc., including its affiliates and subsidiaries (the “Company”) values the confidentiality of personal data. This Privacy Policy details how the Company uses and protects your personal data in accordance with the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), other issuances of National Privacy Commission (NPC) and other relevant laws of the Philippines.

Personal data refers to all types of:

1) Personal information – “any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual”;

2) Sensitive personal information – “personal information about an individual’s race, ethnic origin, marital status, age, color, religious/philosophical/political affiliations, health, education genetic or sexual life, legal proceedings, government issued identifiers and other information specifically established by an executive order or an act of congress to be kept classified”; and

3) Privileged information – “any and all forms of information which, under the Rules of Court and other pertinent laws, constitute privileged communication, such as, but not limited to, information which a person authorized to practice medicine, surgery or obstetrics may have acquired in attending to a patient in a professional capacity”.

Why does the Company collect your personal data?

The Company collects, uses, processes, stores and retains personal data when reasonable and necessary to perform its business processes effectively, safely and efficiently and in accordance with corporate policies.

In general, the Company are using your data for any of the following purposes:

• To comply with the Company’s obligations under law and as required by government organizations and/or agencies
• To comply with legal and regulatory requirements or obligations; and,
• To perform such other processing or disclosure that may be required under law or regulations.

In addition from the general uses mentioned above, we may use your personal information depending on your transactions with the Company in any of the following means:

A. When you want to become part of our team

• To grant access to the Company premises for the performance of individual’s duties and obligations;
• To manage security at the workplace;
• To process employee salaries and benefits;
• To execute employee development, communications, health and engagement programs and organizational planning and management;
• To provide assistance in case of emergency, and to account for employees during emergencies and/or crises;
• To grant access to the Company’s IT systems and infrastructure, consistent with IT policies and procedures;
• To provide access to services, privileges or job opportunities offered by affiliates and subsidiaries of the Company;
• To process requirements for work purposes, including travel, certification, appointments, and the like;
• To conduct internal investigations in relation to security incidents, disciplinary proceedings and other analogous circumstances;
• To comply with government requirements, including permits, disclosures, orders and reports; and
• To perform such other processing or disclosure that may be required in the course of the Company’s business or under law or regulations.

B. When you inquire on our website, social media sites or email:

• To respond to specific complaints, enquiries, requests or to provide requested information;
• Allows us to personalize the site for the user and view how and when specific users visit the site, helping us to improve the site. The use of cookies is an industry standard. Cookies are stored on your computer and are used only to view information on your hard drive that was put there by a cookie from this site. If you do not wish to receive cookies you may set your web browser to prevent them;

C. When you enter the Company premises as guest or visitor:

• To grant access to the Company premises for the performance of individual’s duties and
  obligations;
• To manage security at the workplace;

D. When you are a vendor, a potential vendor, or a contractor:

• To conduct appropriate due diligence checks;
• To evaluate your proposal including your manpower, technical and operational capacity;
• To assess the practicability of your proposal and process your accreditation;
• To communicate the result of your proposal and to execute a letter of award together with the contract;
• To perform any other action as may be necessary to implement the terms and conditions of our contract; and,
• To perform other processes related to or in connection with our business, including those processing or disclosure that may be required under law or regulations.

E. When you become a stockholder of the Company:

• To maintain records of your stocks with the Company;
• To perform administration of your stock transactions

What type of personal data does the Company collect?

The types of personal data that the Company will collect from you depends on the particular purpose and/or position for which you are submitting an application. The common type of data collected by the Company generally includes the following:

• Basic personal information such as name, address, telephone number, and other personal contact details;
• Sensitive personal information such as birth date, marital status, age, religion, nationality, gender, dependents, health information, education, employment history, and government identification numbers, as well as biometric information such as full-face photographs, fingerprints, and other similar images; and
• Privileged information such as medical records

The Company also generate personal data in the course of your employment, such as salary and income, payroll bank account, performance ratings, disciplinary proceedings, training and development activities, medical records and certifications.

Does the Company use web analytics?

This website engaged Google Analytics, a third-party service to analyze the web traffic data for us. This service does not use cookies or web beacons.

Data generated is not shared with any other party. For you to fully enjoy your visit and browsing experience, only non-identifiable web traffic data are collected and analyzed, including:

• Your IP address,
• The search terms you used,
• The pages and internal links accessed on our site,
• The date and time you visited the site,
• Geolocation,
• The referring site or platform (if any) through which you clicked through to this website/page,
• Your operating system, and
• Web browser type.

What about the links to third-party websites?

From time to time, the Company website will provide links to third-party web sites, or advertisements which contain links to third-party sites. These links are provided as a service to you and we do not provide any personal data to these websites or advertisers, and therefore, we will not accept responsibility for their privacy practices. These sites are operated by independent entities that have their own privacy policies which you should also review. First Balfour’s Privacy Policy does not apply to such other sites or to the use that those entities make of your information. First Balfour has no control over the content displayed on such sites, nor over the measures, if any, that are taken by such sites to protect the privacy of your information.

How does the Company collect, acquire or generate personal data?

The Company collect personal data when you:

• accomplish company forms;
• submit to the Company your resume and other employment requirements;
• disclose personal data through phone calls, email, SMS or verbal communication with Company personnel; and

The Company also acquire personal data through third parties, such as:

• Job-search platforms
• Head-hunters
• Universities and professional organizations
• Accredited hospitals or clinics
• Agencies and contractors
• Other companies (such as former employers and affiliates)

The Company generate personal data when you:

• Accept a job offer;
• Avail of benefits; and
• Participate in Company processes and activities.

How does the Company ensure accurate and up to date personal data

Employees are primarily responsible for ensuring that all personal data submitted are accurate, complete and up-to- date. From time to time, the Company requests updated data from the employees.

The Company take reasonable steps to make sure that the personal data the Company collect, generate, use or disclose are accurate, complete, and up-to- date, such as:

• Periodic reviews and audits of systems, processes and data;
• Verification with the concerned employees and third parties

With whom does the Company share personal data?

As a general rule, the Company are not allowed to share your data with a third party except in limited circumstances as noted below.

You authorize the Company to disclose your information to accredited/affiliated third parties or independent/non-affiliated third parties, whether local or foreign in the following circumstances:

• As necessary for the proper execution of processes related to the declared purpose;
• The use or disclosure is reasonably necessary, required or authorized by or under law.

This means the Company might provide personal data to the following:

• Our partner companies, organizations, or agencies including their sub-contractors or prospective business partners that act as our service providers and contractors, consistent with the purposes discussed above;
• Affiliates and subsidiaries of the Company.
• Law enforcement and government agencies;

However, the forgoing may only use such personal data for the purpose(s) disclosed in this Privacy Policy and may not use it for any other purpose.

What is our Privacy Policy regarding children?

The Company is very sensitive to privacy issues and we are especially careful in any communications with one of our most treasured customers – children. The Company would never collect personal data from children directly, without the parent’s consent.

Personal data collected from children is used solely by the Company or other entities that provide technical, fulfillment or other services to the Company. For example, such entities may provide services, such as, improving our services/web sites, and fulfilling requests or administering promotions. These personal data are not sold.

Meanwhile, we urge parents to regularly monitor and supervise their children’s online activities.

How does the Company protect your personal data?

The Company strictly enforces its Privacy Policy. It has implemented technological, organizational and physical security measures to protect personal data from loss, misuse, unauthorized modification, unauthorized or accidental access or disclosure, alteration or destruction. The Company uses safeguards such as the following:

• Use of secured servers and firewalls, encryption on computing devices
• Restricted access only for qualified and authorized personnel
• Strict implementation of information security policies

Where and how long does the Company keep personal data?

The personal data is stored in both local and off-shore facilities, such as data centers (on premise and cloud) and document storage facilities. Data collected will be retained in accordance with the following retention standards, unless you request your data to be deleted in our database immediately. Once deleted, the data will be completely removed from all the storage location.

1. If the data subject has an existing contract and transaction with the Company, information will be retained all throughout the contract period and 15 years after its completion or termination.
2. If the data subject has no existing contract but has existing transaction with the Company, information will be retained during the transaction and 15 years after its fulfillment.
3. If the data subject has no existing contract and transaction with the Company, information will be retained for a retention period of 2 years.

What if there are changes in our Privacy Policy?

From time to time, it may be necessary for the Company to change this Privacy Policy. If we change our Privacy Policy, we will post the revised version here and will take effect immediately, so we suggest that you check here periodically for the most up-to- date version of our Privacy Policy. Rest assured, however, that any changes will not be retroactively applied and will not alter how we handle previously collected personal data without obtaining your consent, unless required by law.

What are your rights under the Data Privacy Act?

As data subjects, you have the following rights:

• Right to be informed;
• Right to object;
• Right to Access;
• Right to Rectify or Correct erroneous data;
• Right to Erase or Block;
• Right to secure Data Portability
• Right to be indemnified for Damages
• Right to File a Complaint

The Company’s decisions to provide such access or consider any request for correction, erasure and objection to process your personal data as it appears in our records are always subject to any exceptions under applicable and relevant laws and/or the DPA, its IRR and other issuances of NPC.

Who should you contact in case of inquiry, feedback or complaints?

Should you have any inquiries, feedback on this Privacy Policy, and/or complaints, you may reach the Data Protection Officer (DPO) through the following contact details:

Data Protection Officer

First Balfour, Inc.

KM 19 West Service Road

Sucat, Paranaque City

1700 Philippines

fbdpo@firstbalfour.com

Tel: +63917 6389 805

You may also lodge a complaint before the National Privacy Commission (NPC). For further details, please refer to NPC’s website: https://privacy.gov.ph.

This Privacy Policy was last amended on January 15, 2018