AdSpark Privacy Policy

1. Privacy Policy
   This Privacy Policy outlines our policy in relation to the collection, use, and protection of your Customer Data to provide you with a delightful customer experience. From time to time, we may update our Privacy Policy to reflect current changes in our policy and the law. When we do so, we will notify you by posting it on our website for your information and reference.By continuing to use our products and services, you signify that you have read, understood, and consented to the collection and use of your Customer Data, particularly your Personal Information, in accordance with this Privacy Policy.
2. Collection of Customer Data
   As part of our continuing relationship with you, we collect your Customer Data, as may be applicable. Customer Data are either Personal Information or Non-Personal Information:
   1. Personal Information is any information from which the identity of an individual can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual, such as name, gender, date of birth, address, telephone/mobile number, email address, proof of identification, etc. It also includes information about:
      1. the services provided to you, such as, call/SMS details, location information, and certain information about your rate plans and features, as required by law;
      2. the location of your device whenever it is switched on, if you subscribe to location based services, subject to coverage limitations; and
      3. your use of our network, network performance experience, diagnostics, such as, signal strength, dropped calls, data failures, and other network performance issues to help us improve our network and quality of products and services, determine tailored content, and for other legitimate business purposes.
   2. Non-Personal Information is any information that does not identify you individually, and includes statistical and analytical data, and anonymous and aggregate reports.

   We may also request you to update your Personal Information from time to time. Should you be unable to supply us with the required Personal Information, we may be unable to provide you with your requested products and services, updates on Globe latest offerings, and you may be unable to participate in our events, promotions or other activities.

   When you use our website and electronically communicate with us, depending on your settings, we may use cookies, web beacons, small data text files or similar technologies to identify your device and record your preferences, with your consent.

3. Use of Customer Data
   Without limiting the generality of the foregoing, we use Customer Data to, among others:
   1. Provide you with your subscribed products and services, including customer support;
   2. Enhance your customer experience and determine tailored content to meet your preferences and needs;
   3. Communicate relevant services and/or advisories to you;
   4. Abide by any safety, security, public service or legal requirements and processes; and
   5. Process information for statistical, analytical, and research purposes.

   We use your Personal Information to the extent necessary to comply with the requirements of the law and legal process, such as a court order; to comply with a legal obligation; or to prevent imminent harm to public security, safety or order.

   We use your Non-Personal Information for statistical, analytical, and research purposes to create anonymous and aggregate reports.

   When required by our Privacy Policy and the law and before we use or process your Customer Data for any other purpose, we will ask for your consent.

   You may avail of our broadcast messages relevant to you through written correspondence, text messaging, internet, or other similar means of communication. You may also change your mind anytime and stop receiving them.

   We outsource or contract the processing of Customer Data to third parties, such as but not limited to, vendors, service providers, partners or other telecommunications operators, to fulfill any of the above purposes. They are only authorized to use Customer Data for such contracted purposes. They may have access to Customer Data for a limited time under reasonable contractual and technical safeguards to limit their use of such information. We require them to protect Customer Data consistent with our Privacy Policy.

4. Protection of Customer Data
   We respect your privacy. We take paramount care in protecting your Customer Data. As such, we secure and protect your Customer Data with proper safeguards to ensure confidentiality and privacy; prevent loss, theft, or use for unauthorized purposes; and comply with the requirements of the law. As communications over the internet may not be secure, we make reasonable and appropriate security arrangements and measures that use a variety of physical, electronic, and procedural safeguards to protect Customer Data. For example, we protect and keep your information submitted through our website safe using a secured server behind a firewall, encryption, and other appropriate security controls. When you enter your information through our website, we encrypt that information using Secure Sockets Layer technology (SSL) so that it cannot be read as the information travels over the internet. We regularly review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to our system and unauthorized alteration, disclosure, or destruction of information we hold.We only permit your Customer Data to be accessed or processed by our authorized personnel who hold such information under strict confidentiality. We restrict access to information to AdSpark employees, contractors, and agents who need to know such information in order to process it for us, who are subject to strict contractual and technical safeguards and are accountable if they fail to meet these obligations.Furthermore, we only give you or your authorized representative access to your Personal Information. We do not sell your Personal Information to anyone for any purpose. We also do not use nor share your Personal Information with content and/or information providers without your prior request or consent. Personal Information will only be disclosed to third parties in accordance with this Privacy Policy.

   We keep our records as accurate as possible. If your Personal Information is wrong, we give you ways to update it. Once you have registered as our customer, you may access your account details and correct your Personal Information by contacting your respective account manager, as may be applicable.

   We keep your Personal Information in our business records, as may be applicable, while you are a customer, or as long as it is necessary to fulfill the purpose for which it was collected, or while it is needed by us for business, tax, or legal purposes. When disposing of your Personal Information, we take reasonable measures to ensure that it is done properly and is not accessible to the public. We are not responsible for information, content, application, product or service that we do not provide. But because we care for you and protect you, we take measures to fight spam, fraud or any unauthorized messages that traverse our network.

   We will report any instances of such activity that we become aware of to the proper authorities as required by law.

5. High-Level Privacy Principles
   In addition, we only want the happiest customers so we commit ourselves to abide by Globe’s high-level privacy principles based on internationally recognized and accepted principles on privacy and data protection as follows: Openness, Transparency, and Notice
   We are open and honest with you and will ensure that you are provided with clear, prominent, and timely information regarding our data privacy practices. We will provide you with information about the collection of your Personal Information, access, sharing, and further use of your Personal Information, enabling you to make informed decisions about whether to use a mobile application or service.Purpose and Use
   We will limit the access, collection, sharing, disclosure, and further use of your Personal Information to meeting legitimate business purposes or to otherwise meet legal obligations. User Choice and Control
   We will give you opportunities to exercise meaningful choice and control over your Personal Information.Data Minimization and Retention
   We will collect, access, and use only the minimum Personal Information necessary to meet legitimate business purposes and to deliver, provision, maintain, or develop applications and services. Personal Information will not be kept for longer than is necessary for those legitimate business purposes or to meet legal obligations, and will subsequently be deleted or rendered anonymous.

   Respect User Rights
   You will be provided with information about, and an easy means to exercise, your rights over the use of your Personal Information.

   Security
   Personal Information will be protected, using reasonable safeguards appropriate to the sensitivity of the information.

   Education
   You will be provided with information about privacy and security issues and ways to manage and protect your privacy.

   Children
   An application or service that is directed at children will ensure that the collection, access, and use of Personal Information is appropriate in all given circumstances and compatible with applicable law.

   Accountability and Enforcement
   All responsible persons will be accountable for ensuring that these principles are met.

6. Contact Us
   For any questions or concerns, you may contact our Privacy Officer as follows:                                                                                                          AdSpark, Inc.
   Bonifacio Global City, 1643 Taguig City,
   Metro Manila, Philippines
   Email: privacy@adspark.ph