This is the FRAME PH Personal Data Protection Policy (“Policy”) which sets forth how FRAME PH (“FRAME PH”) manages, collects, uses and discloses your Personal Data, in accordance with the Philippines Data Privacy Act of 2012 () which regulate how we collect, use, disclose, store, correct, and protect your personal information.
This Policy supplements, but does not supersede, nor replace, any other consents you may have previously provided to FRAME PH in respect of your Personal Data.
- Personal Data
- Purposes for which Personal Information shall be Processed
- Disclosure of Personal Information
- Scope and Method of Processing
- Methods utilized for automated access
- Data Protection
In this Policy, Personal Data refers to any information whether recorded in a material form or not, from which the identity of a Customer 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 a Customer.
When you create a FRAME PH account, the personal information we collect may include your: Name, Email, Gender, Birthday, Mobile Number, and Delivery/Billing Address. When you place an order, we may collect information relevant to your preferred payment method.
PURPOSES FOR WHICH PERSONAL INFORMATION SHALL BE PROCESSED
FRAME PH may collect, use, and disclose your Personal Data to certain third-parties identified below, for the following purposes:
- Fulfillment and delivery of products which you have purchased from FRAME PH, and updating you on the status thereof;
- Processing your orders, including processing thereof for payment;
- Providing you with relevant product information, responding to your queries and requests, and other customer support functions;
- Preventing, detecting, and investigating disputes or fraud, and analyzing and managing commercial risks;
- Analytics and tracking;
- Conducting market research and surveys to enable us to understand and determine customer preferences and demographics, to develop special offers, and marketing programs in relation to FRAME PHs products and services, and to improve customer experience;
- Developing and providing you with additional products, services, and benefits, including promotions, loyalty and rewards programs;
- Advertising and marketing products and services offered by FRAME PH, or relevant products and services from our preferred partners, administering contests, competitions and marketing campaigns;
- Purposes which are reasonably related to the aforesaid; and
- Other legal purposes.
DISCLOSURE OF PERSONAL INFORMATION
Subject to the execution of Data Sharing Agreements in accordance with the Act, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
- FRAME PH’s related corporations, including its parent company, affiliates, and subsidiaries, to provide content, products, and services to you, address your questions and requests in relation to your customer accounts, subscription, and billing or order arrangements, to activate, deactivate, install, maintain and operate our systems and/or services;
- Companies providing consultancy services to FRAME PH;
- Agents, contractors, or third-party service providers that provide operational services to FRAME PH such as courier services, telecommunications, information technology, payment, printing, billing, technical services, training, market research, security, or other services;
- Vendors, partners, or third-party service providers in connection with marketing promotions and services offered by FRAME PH or its preferred partners;
- Commercial shops and retailers in relation to providing rewards and benefits;
- Any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving the Company;
- Our professional advisers such as auditors and lawyers;
- Relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
- Any other party to whom you authorize us to disclose your Personal Data to.
SCOPE AND METHOD OF PROCESSING
Generally, FRAME PH collects Personal Data, either directly from you or from your authorized representatives (i.e. persons whom you have authorized, persons who have been validly identified as being you or your authorized representative pursuant to our then-current security procedures), from third parties, or from publicly available sources or through our website in the following ways:
- When you submit a form for registering as a customer on our website or any other forms relating to any of our products and services;
- When you interact with our customer service team, such as, but not limited to, via telephone calls, letters, face-to-face meetings and emails;
- When you request that we contact you, be included in an email or other mailing list;
- When you respond to our promotions, initiatives or to any request for additional Personal Data;
- When you are contacted by, and respond to, our marketing representatives and customer service team;
- When we receive references from business partners and third parties, such as, but not limited to, where you have been referred by them; or
- When you submit your Personal Data to us for any other reasons.
When you browse our website, you generally do so anonymously except as otherwise described below on automated access
If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.
We may store your personal data while you are a Customer, or as long as may be necessary to fulfill the purpose for which it was collected.
METHODS UTILIZED FOR AUTOMATED ACCESS
When you visit FRAME PH, our company servers will automatically record information that your browser sends whenever you visit a website. This data may include:
- Your computer’s IP address
- Browser type
- Webpage you were visiting before you came to our site
- The pages within FRAME PH you visit
- The time spent on those pages, items and information searched for on our site, access times and dates, and other statistics.
This information is collected for analysis and evaluation in order to help us improve our site and the services and products we provide. This data will not be used in association with any other Personal Data.
As part of the above, FRAME PH may use Google Analytics features based on Display Advertising, including but not restricted to the following: Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting. Using Google Ads Settings (https://www.google.com/settings/ads), you can opt out of Google Analytics for Display Advertising and customize Google Display Network ads.
FRAME PH also uses Remarketing with Google Analytics to advertise online; third-party vendors, including Google, may show FRAME PH ads on sites across the Internet. FRAME PH and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on visitor’s past visits to FRAME PH, as well as report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to FRAME PH.
The Company shall implement reasonable and appropriate organizational, physical and technical measures to protect personal information against accidental loss or destruction, unlawful access, fraudulent misuse, unlawful destruction, alteration, and contamination, including the implementation of an internal data protection policy to ensure compliance with the above measures.
In sharing your personal information with third parties, whether locally or abroad, we will ensure that contractual safeguards are in place for such parties to keep your personal information secure from unauthorized access, collection, use, disclosure, or similar risks and that they retain your personal information only for such limited periods as may be necessary for the purpose.
DELETION OF YOUR PERSONAL INFORMATION
You may also request that we delete any personal information that we have collected from/about you. However, we may retain personal information as authorized under applicable law, such as personal information required as necessary to provide our services, protect our business and systems from fraudulent activity, to debug and identify errors that impair existing functionality, as necessary for us, or others, to exercise their free speech or other rights, comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. We need certain types of information so that we can provide our services. If you ask us to delete it, you may no longer be able to access or use our services.
How to exercise your access and deletion rights
You may exercise your access and deletion rights by submitting your request via email at [email protected]. While email is the best way to reach us, you may also reach us via Whats App at +63 915 908 4178.
If you have an online account with us, logging into your account will serve to verify your identity and request, although we may request additional information if we believe your account has been compromised. If you do not have an account with us, or if we have reason to suspect that the security of your account is compromised, we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.