1. ACENTIVES REWARDS AND PRIVILEGES PROGRAM (“ACENTIVES”)

    ACENTIVES is a benefits platform available for all Ayala Group of Companies (“AGC”)-member Employees and is operated and managed by the Ayala Corp. through its AC Synergy unit. ACENTIVES provides AGC-Member Employees with centralized access to exclusive product and service rewards, privileges, discounts, promotions and deals offered by select AGC-member companies and partner merchants and organizations. In pursuit of these objectives, ACENTIVES may collect and process its members’ personal information, sensitive personal information and privileged information (collectively, “Personal Data”).

  2. PRIVACY STATEMENT

    Inasmuch as ACENTIVES values the individual right to privacy and confidentiality, it ensures that all personal data processed by the program are protected at all times in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (“Data Privacy Act”), its corresponding Implementing Rules and Procedures (“IRR”), and the existing Memorandum Circulars and Advisories issued by the National Privacy Commission (“NPC”). Likewise, we make it a point to inform individuals from whom we collect such data of our personal data processing activities and to respect and enforce their rights as data subjects.

  3. SCOPE OF THE POLICY
    1. This document enumerates ACENTIVES’ policy in relation to the collection, use, storage, sharing and disposal of all personal data processed by the program in accordance with the Data Privacy Act, its IRR, and all related issuances of the NPC.
    2. ACENTIVES maintains the right to amend and/or modify this document to comply with any future developments in local and/or foreign data privacy regulations, where applicable, and to reflect any changes in the organization’s policies and/or personal data processing activities. Thus, you are advised to periodically review our privacy policy for any changes. We will also notify you in-app of any changes to the Privacy Policy. These changes are effective immediately after they are posted.
    3. This document applies, in general, to all personal data processing activities conducted by ACENTIVES, participating AGC-member companies, affiliates, and our partner merchants and organizations including, but not limited to, the collection, use, storage, sharing and disposal of all personal data about participating AGC-member employees.
  4. PURPOSE, SCOPE AND METHOD OF PERSONAL DATA COLLECTION AND PROCESSING

    During the registration process, we collect and process personal data directly from you such as your Full Name, Nickname, Birthdate, Address, Mobile Number, Mobile Phone Operating System, AGC-Member Company, Employee ID Number, Hiring Date, Marital Status, Personal and Ayala-issued Electronic Mail Address and the name and mobile number of your emergency contact. This information is intended for the following purposes:

    1. To help us continuously verify your identity as an AGC-Member Employee while using the platform’s features to ensure security in access, to help us improve/upgrade our systems and processes, to personalize your user experience, and to allow us to maintain accurate records of your personal data with us;
    2. To contact you about any matter (whether through phone calls, mail, email, SMS or any type of electronic facility or communication channel), including updates on featured rewards, privileges, discounts, deals, and/or services offered on the platform;
    3. To provision for and monitor your access to the ACENTIVES platform and use of its featured rewards, privileges, discounts, promotions, deals and/or services;
    4. To create your ACENTIVES profile to help manage all the products, services, benefits and/or privileges which you have availed on the platform; and
    5. To reach out to your nominated contact for any emergency relating to you, your membership to and use of the ACENTIVES platform in the event of your unavailability
    6. We also keep track of your activities on the platform, including the rewards, privileges, discounts, promotions, deals and/or services you redeem from our partner merchants and organizations to give us insight as to what future offers and services you may be interested.

      We collect the above personal data through the following channels:

      1. The ACENTIVES website;
      2. The ACENTIVES Mobile App;
      3. When you interact with our support agents;
      4. When you avail of the offers, promos, and services from select AGC-member companies, affiliates, and partner merchants and organization
      5. When you respond and submit information through surveys sent out during ACENTIVES events or via digital channels (through electronic mail or our website); and
      6. When you provide information in relation to requests, complaints and inquiries,
  5. 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.

  6. AUTOMATED DECISION-MAKING PROCESSES

    We use data analytics and automated processes to determine demographic marketing strategies and approaches. Through the personal data you provide us, we are able to communicate to you rewards, privileges, discounts, promotions, deals and/or services that may be of most interest to you.

  7. COOKIES

    The ACENTIVES platform, through our website, may use cookies to help provide you with a better, faster and safer experience when you use the site. Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are stored in the memory of your device when you visit the Platform. This allows the platform to recognize a device, improve response time and personalize user experience.

  8. RECIPIENTS OF PERSONAL DATA

    Third-party service providers, both within and outside the Philippines, may be provided access to your personal data from time to time for the following reasons:

    • To operate, maintain, secure and further develop the ACENTIVES platform;
    • To provide troubleshooting and assistance services;
    • To provide storage services; and
    • To assist us in analyzing how the ACENTIVES platform is utilized by end-users.

    We understand that under such arrangements, we remain responsible over your personal data as a personal data controller. Nevertheless, we will ensure that any such third-party service provider are contractually obligated to comply with the requirements of applicable privacy laws and regulations.

    We also share your personal data, specifically your contact information, across participating AGC-member companies, affiliates, and other partner merchants and organizations, but only for purposes of allowing them an opportunity to reach out to you for any additional products and/or service offerings they may have. Rest assured, such partner merchants and organizations shall be made contractually obligated to comply with the requirements of applicable privacy laws and regulations, including the return and/or disposal of personal data shared by reason of such partnerships upon termination thereof.

    Apart from the foregoing, we will not disclose any of your personal data to any third party without your permission unless we are compelled or required to do so by applicable law, rules or regulations, or by order of a court of competent jurisdiction or a regulatory agency.

    Should you wish to know more about our third-party service providers, participating AGC-member companies and partner merchants and organizations, please feel free to reach the office of our Data Protection Officer through the contact information provided below.

  9. SECURITY

    While the ACENTIVES platform is operated and managed by AGRN, its design and operation are supported by third-party service providers, specifically in terms of platform operation and maintenance and data storage. Although no system or technology is completely infallible, we have endeavored to take appropriate measures to prevent risks of unauthorized access to your personal data when using the ACENTIVES platform. This includes implementation of appropriate physical, technical and organizational measures in compliance with the requirements of applicable privacy laws and regulations.

  10. 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).

  11. PRIVACY OF MINORS

    We do not knowingly collect personally identifiable information from children under 18 years of age. In instances when we discover that a minor has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that a minor provided us with personal information, please contact us so that we may be able to perform the necessary action.

  12. LINKS TO OTHER SITES

    This ACENTIVES platform may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

  13. PERSONAL DATA RETENTION AND DISPOSAL

    Your personal data will be retained only for as long as is necessary for the fulfillment of the declared, specified, and legitimate purposes provided above, or when the processing is relevant to such purposes, strictly in accordance with our records retention policy. In the event that your membership in ACENTIVES is discontinued/terminated for whatever reason, AGRN shall retain your personal data for a maximum period of one (1) year thereafter for purposes of historical reference unless required by law or when further retention is necessary for the purpose of protecting the organization’s lawful rights and interests from whatever claims and/or liabilities which may arise during this period. After which, your personal data shall be disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public, or prejudice your interests.

  14. YOUR RIGHTS AS A DATA SUBJECT
    1. The Right to be Informed – We honor your right to be informed of the purposes, scope and methods of personal data processing involved in your registration into and use of the ACENTIVES platform. Please note that we are constantly trying to improve and evolve the capabilities of the ACENTIVES platform to include a wider range of programs and services. This could involve changes to the purpose, scope and method of personal data collection and processing relative to your use of the platform. To this extent, we shall endeavor to inform you of any such changes and, when necessary, ask you to review and accept supplemental terms covering new programs and services.
    2. The Right to Object - You have the right to object to the further processing and disclosure of your personal data at any time. You shall be informed of any changes to these Terms and Conditions and your consent obtained thereto, when appropriate.
    3. The Right to Withdraw Consent Anytime - You have the right to withdraw your consent at any time. However, this may affect your membership to the ACENTIVES platform.
    4. The Right to Access, Erasure and/or Blocking - You have the right to request for a copy of any of your personal data processed under these Terms and Conditions. Furthermore, you have the right to have it corrected if you think it is inaccurate or incomplete, subject to the submission of sufficient proof. You have the right to suspend, withdraw or order the blocking, removal or destruction of your personal data should you: (a) discover that it is incomplete, outdated, false, unlawfully obtained, used for an unauthorized purpose, no longer necessary for the abovementioned purposes; (b) withdraw your consent thereto; or, (c) discover violations of your right as a data subject.
  15. CONTACT US

    If you have any questions, concerns, objections about this Privacy Policy, you may contact us directly through the following:

Data Privacy Officer
Contact Information Tel: (632) 908-3346
Fax: (632) 759-4870
Email: acdataprivacy@ayala.com.ph
Office Address 34/F Tower One and Exchange Plaza, Ayala Triangle Ayala Avenue, Makati City
Last Updated 2019-11-14