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Privacy Notice

We, NEC Philippines, Inc. (“NECPH”) recognize the importance of confidentiality and protection of your Personal Information. This Privacy Notice (“Notice”) has been designed to adhere to the relevant transparency requirements of applicable data protection laws and regulations e purpose of this Notice is to inform you how NECPH collects, use, protects, manages or otherwise process your Personal Informationin connection with your relationship with us when you use our, or our customers’, products, services, solutions, through our websites, applications, and online services accessed via your device (e.g., mobile, computer), or through various offline means.

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”). This Notice, however, does not apply to NECPH’s processing activities as data processor, such as when we process Personal Information on behalf of our customers while providing services to them. The contracts we have with our customers control how we process Personal Information in such context. If you are a customer, end-user, employee, or contractor of one of NECPH’s customers and have questions about the processing of your Personal Information, we recommend that you contact our respective customer.

We encourage you to review this Notice, as well as the specific websites, services, or solutions you use. Our data protection policies are tailored to provide specific details relevant to the products, services, or solutions you are interested in and the locations they cover. Rest assured, our commitment to safeguarding your Personal Information is consistent across all our offerings. We are dedicated to maintaining transparency, accountability, and compliance with all relevant data protection laws and regulations.

A.    Personal Information Controller
For the purpose of this Notice NEC Philippines, Inc. is responsible for the processing of your Personal Information as Data Controller.

NEC Philippines, Inc.

Address: 7th Floor 111 Paseo de Roxas Building, Paseo de Roxas Avenue, Makati City 1229 Philippines

If you have any questions about this Notice, your Personal Information or its processing, please reach out to us through the "Contact Us" section.


B.    PERSONAL INFORMATION WE PROCESS

In this Notice, 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:

  • Identity and Contact Data: Your name, your identity card number, passport or other identification number, your photo, or residential address (if applicable).
  • Financial Data: This covers your credit or debit card number and billing information (if applicable).
  • Marketing and Communications Data: This involves information on when you receive and read marketing communications from us, the events you attend, and your marketing and communication preferences. If you provide these preferences in your profile on our electronic portals and platforms, they are considered Profile Data. Additional details about the Personal Information we process for marketing are included with the marketing communications we send you.
  • Profile Data: This includes information you provide on our electronic portals and platforms, such as your usernames and passwords, purchases or orders, interests, biography, profile settings, marketing and communication preferences (e.g., preferred language, content type, frequency of email alerts), alert and display preferences, content that interests you, date of registration, current stage of registration, account status and level of access, and information from forms you fill out, including survey responses and feedback.
  • Usage Data: This encompasses information about your use of our website, electronic portals, platforms, and local area networking facilities and similar electronic services. It includes interactions with our mobile applications and information collected progressively during your visits to our website, electronic portals, and platforms. This data includes your referral website, pages visited, actions taken, last viewed/visited site information, details of the content viewed (including when and how many times it was viewed), patterns of page visits, visit duration, number of visits, time spent on each page, frequency of visits, path followed (sequence of pages visited), interactions, functionalities, modules used, and chat messages.
  • Comments, Feedback, and Other Information You Provide: This includes information you send to customer support, messages, appointment inquiries, and other information you wish to share with us.
  • Technical Data: This includes technical information collected when you access our website or our electronic portals and platforms. It covers your internet protocol (IP) address or domain names of the devices used, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use.
  • Information provided in job applications and related documents when you apply for a position with us.

C.    LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
We only process Personal Information in a lawful and fair manner and when permitted to do so. We receive your Personal Information directly from you, from your employer (e.g., our customer or business partners) or through automated means. We may aggregate your Personal Information to a non-identifiable format and use such data to improve and develop our services and solutions.

Where required under applicable data protection laws and regulations, we rely on one of these legal basis:

  • You have clearly given your voluntary consent to the processing;
  • The processing is necessary for entering into, or performance of a contract to which you are party;
  • The processing is necessary to comply with a legal obligation;
  • The processing is necessary for the performance of a task carried out in the public interest; or
  • We, or a third party, have a legitimate interest in using your Personal Information to achieve the purposes of processing, except where such interests are overridden by your interests or fundamental rights.

Where processing of your Personal Information is based on your consent, you have the right to withdraw your consent at any time by using the mechanism made available to you or by contacting us. Please note that this will not affect processing undertaken prior to the withdrawal of your consent, or any processing based on legal bases other than your consent.

We never collect special categories of Personal Information or sensitive Personal Information about you through our website.

*Where we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide the Personal Information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to decline to provide or receive the relevant services, but we will notify you if this is the case at the time the Personal Information is collected.

1.    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.

D.     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)    Administer certain business pages on social media sites and may act as a joint controller with the social media platform provider when processing Personal Information about visitors to these pages for advertising purposes, even if we do not access any Personal Information.
e)    Assess your interest in job opportunities and communicate with you about potential employment within NECPH;
f)    When you participate, join or attend our marketing, promotional or product demonstration events;
g)    Request information from users via surveys, sweepstakes or contests where participation is voluntary, and users can choose whether to disclose this information. Survey information is used for marketing, monitoring, or improving the use and satisfaction of our websites and services;
h)    Process customer representatives' Personal Information regarding their use of our customer support services to provide a personalized experience on the support platform and continuously improve the user experience of our services.
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.

3.    INTERNATIONAL TRANSFERS
Since NEC Group operates globally and NEC drives a global business, we may transfer your Personal Information outside of the country where you are located. This includes transfers to NEC Group companies, third-party service providers, business partners, or, in limited circumstances, to cooperate with law enforcement or other government agencies worldwide. The countries to which your Personal Information may be transferred may not have data protection laws similar to those of your country. However, we will protect your Personal Information as described in this Notice or as otherwise disclosed to you.

We comply with applicable legal requirements when transferring Personal Information to countries other than the country where you are located. If you are located in the EEA, the UK or Switzerland, we will transfer your Personal Information in accordance with adequacy decisions, standard contractual clauses, and other data transfer mechanisms.

E.    DATA SECURITY
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of individuals, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing.

1. Links to other websites or services
Our websites or services may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through our website or services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through our website. We encourage you to learn about third parties’ privacy and security policies before using their services and providing them with information.

F.    RETENTION OF PERSONAL INFORMATION
NECPH limits the retention of Personal Information to a proportionate period during which the Personal Information is needed to accomplish the purposes for which it was collected or processed. When determining the length of time to retain your Personal Information, we consider several criteria, including whether we need the Personal Information to continue to provide you with our services, enforce our contractual agreements, prevent harm, promote safety, security, and integrity, or protect ourselves, including our rights, property and interests.

We will also retain and use your Personal Information to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies. The retention period may also depend on legal or regulatory requirements applicable to NECPH.

In some circumstances we may anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information without further notice to you.

G.    Minor’s Privacy
Our products, solutions, and services, including our websites, are not intended for minors, and we do not knowingly collect Personal Information from them. If you are a minor, please refrain from using or accessing our services. If we become aware that we have collected Personal Information from a minor without verifiable parental consent, we will take appropriate steps to delete that Personal Information.

H.    DATA PROTECTION RIGHTS
Subject to the Data Privacy Act of 2012, you may have the following rights in relation to your Personal Information:

  • Right to access: You have the right to obtain confirmation on whether NEC processes Personal Information about you and receive a copy of such data, as well as information on how we process your Personal Information.
  • Right to rectification: You have the right to rectify any inaccurate Personal Information we process about you or have any incomplete Personal Information about you completed.
  • Right to erasure. You have the right to have your Personal Information deleted, if (i) the Personal Information has been unlawfully processed; (ii) we no longer need such data for the purposes of the processing; or (iii) the processing is based on consent and you withdraw your consent, and we have no other legal basis for processing the Personal Information. However, NECPH will not delete your Personal Information if NECPH has a legal obligation to retain the data, the Personal Information is still necessary for the purposes of processing, or if NECPH’s legitimate interests override your interests.
  • Right to data portability: You have the right to receive the Personal Information concerning you that you have provided to us in a structured, commonly used, and machine-readable format, and you may have that data ported directly to another controller, where such Personal Information is processed based on your consent or to perform a contract with you.
  • Right to restriction: You have the right to restrict our processing of your Personal Information where you believe that the Personal Information we process is inaccurate or our processing is unlawful. You may also restrict our processing if NECPH no longer needs the Personal Information, but you want us to store the data for the establishment, exercise, or defense of legal claims. You may also require us to restrict the processing of your Personal Information for the period when we assess your right to object to the processing of your Personal Information.
  • Right to object: You have the right to object to our processing of your Personal Information when we rely on our legitimate interests or those of a third party, or if we perform tasks in the public interest in an exceptional case. If you object to our processing, we will cease processing your Personal Information and erase the data, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, or if the data is needed for the establishment, exercise, or defense of legal claims. You always have the right to opt out of receiving direct marketing from us.
  • Right to information: You have the right to receive transparent information about how we process your Personal Information.
  • Right to withdraw your consent: You have the right to withdraw any consent for processing that you have provided at any time. To withdraw consent for cookies, please refer to our Cookies Policy for detailed instructions. To withdraw consent for direct marketing, you can unsubscribe from our direct marketing communications and profiling activities, if applicable. For any other cases, please contact us. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

Please note that a number of these rights only apply in certain circumstances, and all these rights may be limited by law. If you wish to exercise your rights, please reach out to us through the "Contact Us" section.

I.    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.

J.    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.

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

Data Protection Officer (DPO)
NEC Philippines, Inc.
Amendments to the Website Privacy Notice
We may amend this Notice from time to time to keep it up to date with legal requirements and the way we operate our business. We recommend that you visit this Website Privacy Notice on occasion to learn about new data protection practices or changes. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you by means consistent with applicable law and will take additional steps as required by applicable law.

You may also review our Data Privacy Policy, should you need to learn more about this Notice.

This Privacy Notice was last updated: July 2025