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NEC Philippines, Inc. Data Privacy Policy

We, NEC Philippines, Inc. (“NECPH”) recognize the importance of confidentiality and protection of your Personal Information. The purpose of this Data Privacy Policy is to inform you how we collect, protect and manage your Personal Information obtained through our websites, information systems, processes and/or interactions.
NECPH respects the confidentiality of Personal Information and is committed to comply with Republic Act No. 10173 (Data Privacy Act of 2012), its implementing rules and regulations, as well as the relevant issuances from the National Privacy Commission (NPC) (hereinafter referred to as “Data Privacy Laws”). We value the importance of data privacy and shall ensure that all Personal Information collected from our customers, vendors, partners, employees, business associates and contract-binding third parties are processed in compliance with the Data Privacy Laws.

This Data Privacy Policy explains:

  • What information we collect and why we collect it.
  • How we use that information and to whom we may disclose it with your consent.
  • The choices available for you to manage your personal information.
  • How we safeguard your personal information.

By providing your Personal Information through the use of our website, the purchase of our products, solutions and/or services offered by NECPH, you have explicitly consented and authorized the Personal Information to our collection, use, access, transfer, storage and processing.

NECPH will update this Data Privacy Policy as and when required to ensure its continued relevance to any changes in legal or regulatory requirements, industry trends and/or future developments. Subjected to the rights you may have at law, you agree to be bound by the prevailing terms of the Data Privacy Policy as updated from time to time on our website. We strongly encourage you to visit our website from periodically to obtain updated information of this Data Privacy Policy.

A.    PERSONAL INFORMATION WE COLLECT
Personal Information refers to “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” (Data Privacy Act of 2012, Section 3g).
Such Personal Information (depending on the nature of interaction with NECPH) include, amongst others: your name, your identity card number, passport or other identification number, your photo, residential address, device identifiers, IP addresses, credit history and/or other  information that can be used to ascertain your identity.

1.    Consent
NECPH shall seek your explicit consent when requesting your Personal Information for the specific purpose(s) the Personal Information is intended for. By providing your Personal Information, you confirm your agreement to the terms and conditions documented in this Data Privacy Policy. Your rights under the Data Privacy Laws shall be upheld when invoked by your lawful heirs or assigns.
By providing your Personal Information, you confirm your agreement to the terms and conditions contained in this Data Privacy Policy. Your rights under this Data Privacy Policy shall be upheld when invoked by your lawful heirs or assigns.

2.    Personal Information
As part of our interactions with you, we may collect your Personal Information including, but not limited to, the following, and we may collect such Personal Information in various ways such as:

a)    Your name, company name, designation, contact details, email address and any other information relating to you which you have provided us in any form, whether through manual or electronic submission, as result of our interaction with you through our marketing, sales and/or promotional events;
b)    Your name and image captured using our image capturing solutions during promotional and/or demonstration events;
c)    Your name and signature using manual registration form when you visit our office;
d)    Your employment history, education background, resume and income information when you apply for a job with NECPH;
e)    Information about your visit and use of our website and digital platforms including, but not limited to, social media profile information, IP Addresses, your browsing behavior within and throughout our digital assets, and session lengths, that are collected by our website analytics tools and cookies that we may place on your computer. You may disable the use of cookies on your browser at any time;
f)    Your social media postings when you tag, mention, or post photographs of any NECPH developments/ activities/ events publicly on any social media platform (e.g. Facebook, Twitter, Instagram, LinkedIn, etc.); and
g)    Your Personal Information and other data in relation to the purchase of any of our products, solutions, services, or interactions during activities, events or for any other reasons.

3.    Personal Information Other Than Yours
When you disclose to us another person’s Personal Information (such as, but not limited to, that of your dependent, spouse, children and/or parents, employer and/or employees, colleagues, referrals and/or personal references), you attest that consent has been obtained from that person to disclose and process their Personal Information in accordance with this Data Privacy Policy.


B.    USE AND DISCLOSURE OF PERSONAL INFORMATION

1.    Uses of Your Personal Information
NECPH may collect, use and disclose your Personal Information for the following purposes:
a)    Provide you with information about our product, solutions and services that you have requested, including customer support;
b)    For the implementation and delivery of our products, solutions and/or services that you purchased;
c)    Communicate relevant services, advisories including responses to your queries, requests and complaints;
d)    When you become our customer, service provider, contractor, vendor;
e)    When you apply for employment, or become our employee or are deployed to us by our service providers/ contractors;
f)    When you participate, join or attend our marketing, promotional or product demonstration events;
g)    Comply with the requirements of the law and legal proceedings such as court orders, comply with legal obligation or to prevent imminent harm to public security safety or order;
h)    To prevent, detect and investigate crime, including fraud and money-laundering, and to analyze and manage other commercial risks;
i)    Process information for statistical, analytical, reportorial and research purposes; and
j)    Purposes which are reasonably related to any of the above-mentioned situations or for any other purpose which we may notify you at the time of obtaining your consent.

2.    DISCLOSURE OF YOUR PERSONAL INFORMATION
We may disclose your personal information to the following, if necessary, based on specified and legitimate purposes determined and declared before, or as soon as reasonably practicable after, collection of your Personal Information:
a)    Our employees, officers, directors and management;
b)    Professional advisers such as lawyers and auditors;
c)    Banks, insurers and credit providers;
d)    Our clients and/or customers;
e)    Suppliers, vendors, and third party service providers, that have been contracted by NECPH to provide financial, technical, legal, administrative services such as information technology, payroll, accounting, sales administration, procurement, training and other services;
f)    We may likewise disclose your personal information to the following, if necessary, based on specified and legitimate purposes determined and declared before, or as soon as reasonably practicable after, collection of your Personal Information:
•    Members of the NEC group of companies;
•    Our Parent company NEC Corporation and all its subsidiaries and affiliates;
g)    We may disclose your personal information:
i)    For any ongoing or prospective legal proceedings; and
ii)    As required by applicable law and/or rules and regulations, subject to the limitations and requirements under the Data Privacy Laws.
Where necessary, NECPH will require any person and/or entity to whom your personal information is provided to agree to comply with our Data Privacy Policy. While we will use all reasonable efforts to ensure that such persons and/or entities comply with our Data Privacy Policy, we will not be liable to you if any person and/or entity fails to do so.

C.    STORING YOUR PERSONAL INFORMATION AND ITS SECURITY

1.    Physical Storage
Personal Information that we collect from you through paper-based forms, registration sheets, or as contained in other paper-based documents, will be physically stored and secured within the NECPH office.
2.    Servers
Personal information that we collect from you through laptops, mobile and other digital applications, or online-based forms are stored in our servers. Said servers are physically located within the NECPH office.
3.    Cloud Services
We may utilize cloud services to store the information we collected from you in order to enable us to use the information in accordance with this Data Privacy Policy and subject to the restrictions and guidelines provided under Data Privacy Laws.
4.    Internet
Personal information that you publish on our website or you submit on our website may be available, via the internet, around the world.
a)    You understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our websites, online Services and apps; any transmission is at your own risk.
b)    Additionally, we cannot assume responsibility for any unauthorized use of your Personal Data by third parties which are wholly attributable to factors beyond our control.

D.    Retention & Disposal of Personal Data

1.    We will retain documents (including electronic documents) containing your personal data:
a)    to the extent that we are required to do so by law;
b)    to the extent required by or pursuant to our contract;
c)    if we believe that the documents may be relevant to any ongoing or prospective legal proceedings.
2.    Thereafter your personal information shall be disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public.

E.    ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

1.    ACCESSING YOUR PERSONAL INFORMATION
You may instruct us to provide you with any Personal Information we hold about you. Provision of such information will be subject to the supply of appropriate evidence of your identity.
a)    We may withhold personal information that you request to the extent permitted by law.
b)    You may instruct us at any time (i) not to process your personal information for marketing purposes, (ii) not to disclose your Personal Information to any of those above-mentioned, or (iii) to remove your Personal Information from our files or delete/destroy documents containing your Personal Information, as applicable.
c)    In practice, you will either expressly agree in advance to our use of your personal information for marketing and promotional purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
d)    For Personal Information other than yours which you provided us or we collect from you, presumably with the consent given to you by the data subject for the use and processing of his/her Personal Information, we may withhold said Personal Information despite your request unless you can show us proof that the data subject consents for us to disclose the Personal Information to you.

2.    UPDATING YOUR PERSONAL INFORMATION
a)    If the personal information that we hold about you needs to be corrected or updated, NECPH shall make all reasonable efforts to ensure that data collected is current, complete and accurate. If you want to access and update your personal data, or otherwise instruct us regarding the use, retention or disclosure of your Personal Information, you may send the request to our Data Protection Officer at necph.dpo@nec.com.ph with your complete name and contact details. Said information provided in the email shall be used solely for the purpose of verifying your identity and implementing your request.
b)    As part of our security measures, we will contact you and conduct the necessary verification measures to process your request. Once we have implemented the necessary correction we shall then notify you that your request/s have been processed.
c)    If your request is for correction or update of your Personal Information, we will retain your email request together with the Personal Information in our email servers. If your request is for deletion of your Personal Information or destruction of copies containing your Personal Information, we will immediately delete your email request as soon as your request has been implemented.

3.    WITHDRAWAL OF CONSENT
If you wish to withdraw your consent given for any or all purposes set out in this Data Privacy Policy, you may send your detailed request to our Data Protection Officer at necph.dpo@nec.com.ph. Depending on the nature of your consent withdrawal and the purpose of our collection of your Personal Information, NECPH may not be in a position to continue to provide our products, solutions and services to you.

F.    PROTECTING YOUR INFORMATION

1.    PROTECTING INFORMATION YOU SUBMIT ONLINE
We shall take the necessary due diligence and precautions to protect the collected Personal Data your personal data. When you submit sensitive information through online forms, mobile or digital platforms or through our website, such information is protected both online and offline.
While we employ all necessary precautions to safeguard your information, the Internet is not 100% secure so we cannot guarantee that information we collect or store will be protected from all unauthorized access and thereby used in a manner that is not inconsistent with this Data Privacy Policy.

2.    HOW WE SAFEGUARD YOUR PERSONAL INFORMATION
We maintain physical, technical and organizational safeguards to protect your personal data against loss, theft, unauthorized access, disclosure, copying, use or modification. We also put in effect safeguards such as:
a)    Using secured servers and firewall.
b)    We limit access of your personal information to those who are qualified and authorized to process them. All such persons, wherever they are located, are required by us to protect the confidentiality and privacy of your personal information in a manner consistent with our privacy policies and practices.
c)    Our information system/infrastructure undergo regular security vulnerability and penetration testing to ensure your personal information is properly protected.

G.    AFFILIATES OR THIRD PARTY WEBSITES
Our website may contain hyperlinks and details of affiliates’ websites or third party websites. We have no control over, and are not responsible for, the privacy policies and practices of the entities owning the websites you visit by clicking the hyperlinks and leaving the NECPH website.
We therefore advise you to study their privacy policy. Once you leave our website, you should check the applicable privacy policy of the website to determine how they will handle any information they collect from you.

H.    COOKIES AND SIMILAR TECHNOLOGIES
Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website. We only use this information for statistical analysis purposes, after which the data is removed from the system.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

I.    HOW TO CONTACT US
For any comments, questions, complaints or requests relating to this Data Privacy Policy, you may get in touch with:

Data Protection Officer (DPO)
NEC Philippines, Inc.