This page informs you of the privacy policy of AYALA GROUP CLUB, INC., doing good under the name and style of Ayala Rewards Circle (“ARC”). ARC is a non-profit corporation, the purposes of which are to encourage a closer and more active fellowship and promote social interaction among its members; develop goodwill among its members; promote and encourage civic participation, community involvement, nation-building, consumer awareness and protection, and freedom of choice among its members; and in pursuit of the foregoing, to develop and administer programs for the benefit of its members, conduct and transact any and all lawful activities, and to do or cause to be done any act necessary, desirable or incidental to the accomplishment of these purposes. In pursuit of these, ARC may process its members’ personal information, sensitive personal information and privileged information (collectively, “Personal Data”).

ARC values its members’ privacy and the confidentiality of each of its member’s Personal Data. It also remains committed to comply with the Data Privacy Act of 2012 (“DPA”), enacted by Congress in August 2012 as Republic Act No. 10173, and its Implementing Rules and Regulations (“IRR”), issued by the National Privacy Commission.

Through this privacy policy, ARC explains:

• the nature, purpose and extent of processing of Personal Data;
• the parties to whom ARC may disclose and share its members’ Personal Data and from whom ARC may validly obtain Personal Data with consent;
• the risk of processing and data security measures in place to protect you against these risks;
• the period within which its members’ Personal Data will be processed and retained.

Personal Data

The Personal Data that ARC processes are as follows:

• your name, age, date of birth, marital status, contact details, and any other information relating to you which you have provided us in submission of any form.
• any information about your visit and use of our website, mobile app, social media site and other digital platforms. This includes the collection of information through website analytics tools, IP addresses, and cookies and social media behavior when you tag, repost or mention ARC or Ayala Rewards Circle and its subsidiaries and partners on any social media account.

Consent

By providing ARC with your Personal Data in the use of any of our services or programs, or through your continued membership to ARC, you confirm your agreement to the terms and conditions in this Privacy Policy, you have explicitly authorized and consented to our processing of your Personal Data.

Collecting Personal Data

ARC may collect your Personal Data through the following ways:

• when you submit your Personal Data through any form (e.g. registration form), through the website and mobile application;
• when you interact with our concierge agents through phone, email, chat and social media accounts (e.g. Facebook);
• when you avail of the offers, promos, benefits, services from partner merchants and Ayala subsidiaries;
• when you respond and submit information through surveys sent out during ARC events or via digital channels (through email or mobile application);
• when you provide information in relation to requests, complaints and inquiries

Personal Data Other than Yours

When you submit to us another person’s Personal Data (e.g. your spouse, dependent, children, parents), you attest that consent has been obtained by such person to process his or her Personal Data in accordance with this privacy policy.

Use and Disclosure of Personal Data

ARC uses and processes your Personal Data for the following:

• its marketing, communication, analysis and research objectives for purposes of providing privileges, promotional offers and benefits to its members;
• providing rewards/ privileges to its members: or
• determining suitable promos, activities and products to its members.

ARC may disclose its member’s Personal Data to its employees, duly authorized representatives, related companies (including member-companies), assignees and third-party service providers.

Protection of Your Personal Data

ARC is committed to protecting the privacy of all Personal Data submitted and provided by its members including information transferred to third parties performing services on behalf of ARC.  ARC processes Personal Data in adherence to the general principles of transparency, legitimate purpose and proportionality.

Any information you choose to provide us (for example, by filling out the online registration form or a survey or sending us e-mail) shall be used only for the declared purpose for its collection. Your activity on our website will not result in your being added to a mailing list, unless you specifically request us to do so. We will not provide or sell any information from any of our surveys, e-mail lists, or electronic forms to any third party.

All such persons or service providers, are required to protect the confidentiality and privacy of all Personal Data in line with the privacy policy of ARC. Safety measures shall be maintained to ensure protection of Personal Data against disclosure, loss, theft, unauthorized access, modification or usage, such as password encryption of files, restricted file access to a limited number of employees, firewall security and regular audit trails.

ARC has procedural and electronic safeguards and security tools, such as password encryption of files, restricted file access to a limited number of employees, firewall security and regular audit trails in place to help secure your online Personal Data from unauthorized use. Although these systems are in place to adequately protect the data, these may still be subject to human and operational error and is not completely infallible. ARC has taken measures to prevent unauthorized access, improper processing or usage of your Personal Data through these measures.

Withdrawal of Consent

If you wish to withdraw your consent given to ARC, you may send your request to dpo@ayalarewardscircle.com. Depending on the nature of the consent you wish to withdraw, ARC may not be in a position to continue to extend our benefits and services to you.

Third Party Websites

Sites accessed by hypertext links appearing in ARC’s website may have been independently developed by others. We have no control over, and are not responsible for, the privacy and policies and practices of third parties. This privacy policy only applies to ARC’s website, so when you link to other websites, we advise you to study their own privacy policies.

International Data Transfers

• Internet

 Personal Data submitted or published (e.g. Profile page) in the ARC website may be available around the world through the internet. We have no control over the use and misuse of such information by others.

• Cloud Services

Personal Data that we process may be stored in and transferred to countries in which we make use of cloud services (e.g. Salesforce).

Cookies and Similar Technologies

ARC website uses cookies – small amount of data, which may include an anonymous unique identifier which are stored in the memory of your device when you visit the ARC website. This allows the ARC website to recognize a particular device to improve the user experience and make the website work more efficiently as well as to provide information to the owners of the site. These cookies are encrypted and do not save any Personal Data about you. If you disable or block cookies, you will be unable to access the full features of the ARC website.

Contact Us

If you have questions about this letter, ARC’s Privacy Policy Statement, or ARC’s data processing activities, you can contact us by sending us an email at dpo@ayalarewardscircle.com