NOTICE IN COMPLIANCE WITH

REPUBLIC ACT 10173 (DATA PRIVACY ACT OF 2012)

 

This Privacy Notice (“Notice”) describe how AUTONOMOUS INSPECTION CENTRE INC. (Autonomous) and/or PARK SOLUTIONS INC. (PSI) collect, use, process and disclose your Personal Information through the use of the mobile application known as ORO Wallet, and web-application portals, as well as products, such as physical card known as ORO Kard, and other mobile, or automated services offered by Autonomous and/or PSI under the following products:

 

1.    ORO Kard - Brand Name of the full ecosystem used by affiliated transport terminals;

2.    ORO Kard Card - Physical Card for Passenger Use; and

3.    ORO Wallet - Mobile Application for Passenger Use

 

This Notice applies to all consumers, clients, agents, vendors, suppliers, partners (such as operators, drivers and merchant partners), contractors and service providers.

 

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. This includes but is not limited to an individual’s name, nationality, telephone number, bank and credit card details, personal interests, email address, image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information and financial information.

 

I.    COLLECTION OF PERSONAL INFORMATION

 

Autonomous and/or PSI collect Personal Information about an individual in the ways listed below. They may also combine the collected Personal Information with other Personal Information in their possession. If an individual has, or is a party to multiple relationships with Autonomous and/or PSI, they will link an individual’s Personal Information collected across an individual’s various capacities to facilitate his use of the offered services and for the purposes described below.

 

Autonomous and/or PSI collect Personal Information when an individual voluntarily provides it to them in the following ways:

 

     completes a user profile or registration forms (such as his/her name, contact information and other identification information where needed);

     provides information to assess his/her eligibility or qualification to avail of the mobile, or automated services offered by Autonomous and/or PSI;

     interacts with Autonomous’ and/or PSI’s social media pages (such as his/her social media account ID, profile photo and any other publicly available data);

     participates in contests, redemption of loyalty points, rewards and/or events organized by Autonomous and/or PSI (such as the pictures, audio files, or videos he/she may submit, which may include images of himself/herself);

     verifies his/her identity through various means (such as social media logins, submission of selfie images or independently verified payment card information);

     fills up demographic information in surveys (such as age, gender, and other information he/she may volunteer such as his/her marital status, occupation and income information); and

     agrees to take a ride with in-vehicle audio and/or video recording features.

 

In certain circumstances, an individual may need to provide his/her Personal Information in order to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. Failure to provide such Personal Information, under such circumstance, may constitute failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with an individual.

 

For purposes such as detection and prevention of fraud, Autonomous and/or PSI may also collect an individual’s Personal Information without consent, as provided under Republic Act 10173 (Data Privacy Act of 2012), and other applicable laws.

 

Personal Information may be collected through the normal operation of Autonomous’ and/or PSI’s Apps, Websites and Services.

 

When Autonomous and/or PSI collect Personal Information, including but not limited to an individual’s name, contact information and other identification information where needed from other sources, Autonomous and/or PSI make sure that that data is transferred to them in accordance with Republic Act 10173 (Data Privacy Act of 2012), and other applicable laws.

 

Some of the Personal Information that Autonomous and/or PSI collect is sensitive in nature. This includes Personal Information pertaining to an individual’s national ID information, religious beliefs, background information (including financial and criminal records, where legally permissible), health data, disability, marital status and biometric data, as applicable. Autonomous and/or PSI collect this information only with an individual’s consent and/or in strict compliance with Republic Act 10173 (Data Privacy Act of 2012), and other applicable laws.

 

Personal Information of minors

 

A parent or legal guardian must not allow minors under their care to submit Personal Information to Autonomous and/or PSI. In the event that such Personal Information of a minor is disclosed to Autonomous and/or PSI, his/her parent or legal guardian consents to the processing of his/her Personal Information and accepts and agrees to be bound by this Notice and take responsibility for his/her actions.         

 

Personal Information of other individuals

 

In some situations, an individual may provide Personal Information of other individuals (such as his/her spouse, family members or friends) to Autonomous and/or PSI. In such cases, the individual who provided the Personal Information of other individuals represents and warrants to Autonomous and/or PSI that he/she has obtained their consent for their Personal Information to be collected, used and disclosed as set out in this Policy.

 

II.    USE OF PERSONAL INFORMATION

 

Autonomous and/or PSI may use, combine and process an individual’s Personal Information for the following purposes:   

     to provide, personalize, maintain and improve their apps, websites and services;

     to ensure the safety and security of their apps, websites and services and all users

     to resolve user support issues;

     for testing, research, analysis and product development;

     to investigate and resolve claims, or disputes, or as allowed or required by applicable laws;

     when required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority;

     in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of Autonomous’ and/or PSI’s business by another company; and

     to market Autonomous’ and/or PSI’s products, services, events or promotions

 

III.    RETENTION OF PERSONAL INFORMATION

 

Autonomous and/or PSI retain an individual’s Personal Information for the period necessary to fulfill the purposes outlined in this Notice, unless a longer retention period is required or allowed by Republic Act 10173 (Data Privacy Act of 2012), and other applicable laws. Once an individual’s Personal Information is no longer necessary, or Autonomous and/or PSI no longer has a legal or business purpose for retaining an individual’s Personal Information, they will take steps to erase, destroy, or prevent access or use of such Personal Information for any purpose other than compliance with this Notice, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of Republic Act 10173 (Data Privacy Act of 2012), and other applicable laws.

 

IV.    COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS

 

Autonomous and/or PSI, and third parties with whom they partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies in connection with an individual’s use of its websites and apps. Depending on the type of phone and operating software that an individual is using, he/she may be granted the option to disable Autonomous’ and/or PSI’s use of mobile identifiers (such as Apple’s IDFA). Cookies may have unique identifiers, and reside, among other places, on an individual’s computer or mobile device, in emails Autonomous and/or PSI send to him/her, and on the former’s web pages. Cookies may transmit Personal Information about an individual and his/her use of the former’s services, such as his/her browser type, search preferences, IP address, data relating to advertisements that have been displayed to him/her or that he/she has clicked on, and the date and time of his/her use. Cookies may be persistent or stored only during an individual session.

 

Autonomous and/or PSI may allow third parties to use cookies on their websites and apps to collect the same type of Personal Information for the same purposes. Third parties may be able to associate the Personal Information they collect with other Personal Information they have about an individual from other sources. Autonomous and/or PSI do not necessarily have access to or control over the cookies they use.

 

Additionally, Autonomous and/or PSI may share non-personally identifiable Personal Information with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.

 

An individual may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting his/her browsing history and clearing the cache from his/her internet browser.

 

An individual may be able to limit Autonomous’ and/or PSI’s use of his/her Personal Information to display advertisements that may be of relevance to him/her, by adjusting his/her preference sharing of some of this Personal Information through their ORO Wallet App (Settings > Privacy > Ads). An individual will still be seeing non targeted advertisements.

 

V.    PROTECTION OF PERSONAL INFORMATION

 

Autonomous will take reasonable legal, organizational and technical measures to ensure that an individual’s Personal Information is protected. This includes measures to prevent Personal Information from getting lost, or used or accessed in an unauthorized way. They limit access to an individual’s Personal Information to their employees on a need to know basis. Those processing an individual’s Personal Information will only do so in an authorized manner and are required to treat his/her information with confidentiality.

 

The transmission of information via the internet is not completely secure. While Autonomous and/or PSI will do their best to protect an individual’s Personal Information, they cannot guarantee the security of his/her Personal Information transmitted through any online means, therefore, any transmission remains at his/her own risk.

 

VI.   AN INDIVIDUAL’S RIGHTS WITH RESPECT TO HIS/HER PERSONAL INFORMATION

   

An individual providing Personal Information is entitled to:

 

·         Be informed whether Personal Information pertaining to him/her shall be, are being or have been processed;

·         Be furnished the information indicated hereunder before the entry of his/her personal information into the processing system of the personal information controller, or at the next practical opportunity:

o   Description of the personal information to be entered into the system;

o   Purposes for which they are being or are to be processed;

o   Scope and method of the personal information processing;

o   The recipients or classes of recipients to whom they are or may be disclosed;

o   Methods utilized for automated access, if the same is allowed by the data subject, and the extent to which such access is authorized;

o   The identity and contact details of the personal information controller or its representative;

o   The period for which the information will be stored; and

o   The existence of their rights, i.e., to access, correction, as well as the right to lodge a complaint before the National Privacy Commission (NPC).

Any information supplied or declaration made to the data subject on these matters shall not be amended without prior notification of data subject: Provided, That the notification, regarding the purposes for which the Personal Information are being or are to be processed shall not apply should the personal information be needed pursuant to a subpoena or when the collection and processing are for obvious purposes, including when it is necessary for the performance of or in relation to a contract or service or when necessary or desirable in the context of an employer-employee relationship, between the collector and the data subject, or when the information is being collected and processed as a result of legal obligation;

 

·         Reasonable access to, upon demand, the following:

o   Contents of his/her personal information that were processed;

o   Sources from which personal information were obtained;

o   Names and addresses of recipients of the personal information;

o   Manner by which such data were processed;

o   Reasons for the disclosure of the personal information to recipients;

o   Information on automated processes where the data will or likely to be made as the sole basis for any decision significantly affecting or will affect the data subject;

o   Date when his/her personal information concerning the data subject were last accessed and modified; and

o   The designation, or name or identity and address of the personal information controller;

·         Dispute the inaccuracy or error in the Personal Information and have the personal information controller correct it immediately and accordingly, unless the request is vexatious or otherwise unreasonable. If the Personal Information have been corrected, the personal information controller shall ensure the accessibility of both the new and the retracted information and the simultaneous receipt of the new and the retracted information by recipients thereof: Provided, That the third parties who have previously received such processed personal information shall he informed of its inaccuracy and its rectification upon reasonable request of the data subject;

·         Suspend, withdraw or order the blocking, removal or destruction of his/her Personal Information from the personal information controller’s filing system upon discovery and substantial proof that the Personal Information are incomplete, outdated, false, unlawfully obtained, used for unauthorized purposes or are no longer necessary for the purposes for which they were collected. In this case, the Personal Information controller may notify third parties who have previously received such processed personal information; and

·         Be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of Personal Information.

 

VII. AMENDMENTS AND UPDATES

 

Autonomous and/or PSI may modify, update or amend the terms in this Notice at any time. Such amendments shall be notified to an individual through the Application and/ or other appropriate means at least five (5) business days before the effective date. The updated version will be posted on Autonomous’ and/or PSI’s website. It is an individual’s responsibility to review the Privacy Notice regularly. An individual’s continued use of the Apps, Websites or Services, purchase products from Autonomous and/or PSI, or continuing to communicate or engage with Autonomous and/or PSI following the modifications, updates or amendments to this Notice, whether or not reviewed by him/her, shall constitute his/her agreement to be bound by such amendments.