privacy.html

Data Controller and Owner

Strategic Intelligence Technology Solution, Inc
Basement, Philippine-Korean Friendship Center,
Bayani Road, Fort Bonifacio,
Taguig City, Philippines
Owner contact email: cs@sits.ph

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Approximate location permission (non-continuous),

Precise location permission (non-continuous), Phone permission, SMS permission and Storage permission.

Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection.

The Personal Data may be freely provided by the User, or collected automatically when using this Application.

Any use of Cookies - or of other tracking tools - by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.

Failure to provide certain Personal Data may make it impossible for this Application to provide its services.

Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Place

The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of the collected Data

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Device permissions for Personal Data access.

The Personal Data used for each purpose is outlined in the specific sections of this document.

Device permissions for Personal Data access

This Application requests certain permissions from Users that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.

The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of this Application.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.

Approximate location permission (non-continuous)

Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.

The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the approximate position of the User on a continuous basis.

Phone permission

Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the "phone state", which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.

Precise location permission (non-continuous)

Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services.

The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the exact position of the User on a continuous basis.

SMS permission

Used for accessing features related to the User's messaging including the sending, receiving and reading of SMS.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Device permissions for Personal Data access

This Application requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (This Application)
This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data collected: Approximate location permission (non-continuous), Phone permission, precise location permission (non-continuous), SMS permission and Storage permission.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.

The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users
Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

This Application does not support "Do Not Track" requests.

To determine whether any of the third party services it uses honor the "Do Not Track" requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Information about this privacy policy

The Data Controller is responsible for this privacy policy.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The hardware or software tool by which the Personal Data of the User is collected.

DATA PRIVACY ACT POLICY

Version 1 | August 1, 2021

This Policy defines the commitment of Strategic Intelligence Technology Solutions, Inc to collect and process personal data in compliance with Republic Act No. 10173 or the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and other relevant policies.

It aims to inform clients, employees, partners and stakeholders of SITS SOS’s data protection and security measures, and to guide them in the exercise of their rights under the DPA and other relevant regulations and policies.

PROCESSING OF PERSONAL DATA

A. Collection

SITS SOS collects the following various types of information;

From Clients. This includes information used to identify and contact the client such as name, job title, company name, company address, email address and phone number.
From Job Applicants. This includes information used to identify and contact the applicant such as name, home address, email address and phone number.
From Business Parties and Third Parties. This includes information used to identify and contact our business partner such as name, job title, company name, company address, email address and phone number.
From Cookies and Similar Technologies. This includes technical data collected from analytics, cookies, tracking and similar technologies such as device used, IP address, links visited and other similar information

B. Use

SITS SOS collects and maintain personal data for the purposes of;

o To perform our obligations per service agreement. We collect personal data to verify your identity to ensure accurate delivery of our products and services. Such data is also used for billing and collection of fees for the product and services provided.

o To provide business operations support. We analyze your usage of our facilities to provide operational support to your account, offer customer service activities, and address your requests and concerns. We may also process your personal contact details in our database to effectively communicate with you for proper assistance.

o To continuously improve our products and services. We collect, use, and process your use of our products and services so that we can better understand and improve them for your benefit. It gives us better insight about the kinds of offers that would be relevant to your needs.

o To secure our business operations. We may process your personal data to conduct security operations check to ensure fair use of our products and services, for business continuity and audits purposes.

o To conduct online marketing. We use your personal data to effectively communicate and provide offers and promotions.

o To comply with legal requirements. We use and process personal data to address legal issues such as complying to our obligations to retain business records for a minimum retention periods, complying with laws, regulations and other legal process, violation of our agreements and protecting SITS SOS’s and your rights, property, welfare, health and safety.

Storage, Retention and Destruction

SITS SOS will ensure that personal data under its custody are protected against any accidental or unlawful destruction, alteration and disclosure as well as against any other unlawful processing. SITS SOS will implement appropriate security measures in storing collected personal information, depending on the nature of the information. All information gathered shall not be retained for a period longer than one (1) year. After one (1) year, all hard and soft copies of personal information shall be disposed and destroyed, through secured means.

Access

SITS SOS values the sensitivity and confidentiality of the personal data under our custody, thus we ensure that SITS SOS maintains reasonable safeguards to protect your personal data. Only you and authorized representative from SITS SOS shall be allowed to access such data from our database for any purpose, except for those contrary to law, public policy, public order or morals.

Disclosure and Sharing

All SITS SOS employees and personnel shall maintain the confidentiality and secrecy of all personal data that come to their knowledge and possession, even after resignation, termination of contract, or other contractual relations. Personal data under the custody of the company shall be disclosed only pursuant to a lawful purpose, and to authorized recipients of such data.

SECURITY MEASURES

SITS SOS shall appoint a Data Protection Officer (DPO) who will be responsible in ensuring the organization’s compliance with applicable laws and regulations for the protection of data privacy and security. The DPO is responsible for the supervision and enforcement of this Policy.

In accordance to the enforcement of our Privacy Policy within the organization, SITS SOS has implemented technical, organizational, and physical security measures that are designed to protect personal data from unauthorized or fraudulent access, alteration, disclosure, misuse, and other unlawful activities. These are also designed to protect personal data from other natural and human dangers.

SITS SOS put in effect the following safeguards on personal data;

Protect in a secured server
Maintain as long as necessary to (a) provide the products and services, (b) for legal business purposes, (c) to comply with pertinent laws, and (d) for special cases that will require the exercise or defense of legal claims and for a defined retention period after termination of service
Restrict access to personal data to qualified and authorized personnel who are trained to handle the data with strict confidentiality;
Regular audits and testing of infrastructure’s security protocols to ensure data is always protected;
Notify concerned individual and the competent data protection authority, when sensitive personal data that may, under the circumstances, be used to enable identity fraud are reasonably believed to have been acquired by an unauthorized person;
Allow update of information securely to keep our records accurate.

RIGHT OF DATA SUBJECT

As identified under DPA, data subjects have the following rights in connection with the processing of personal data

Right to object. Data subject has the right to refuse to the processing of personal data including processing for direct marketing, automated processing or profiling.
Right to access. Upon request, you may be given access to your personal data that has been collected and processed.
Right to rectification. Data subject has the right to dispute any inaccuracy or error in his/her personal data, and the organization shall correct it immediately and accordingly, unless the request is unreasonable.
Right to erasure. Data subject has the right to request the erasure of the personal date, such as in cases where the personal data is no longer necessary to achieve legitimate purpose of its use for processing
Right to restrictions. This right entitles data subject to request to only process data in limited circumstances, including consent given.
Right to data portability. Data subject has the right to receive a copy of personal data that have been provided to us, as well as, transmit a copy of such data to another company on data subject’s behalf.

BREACH AND SECURITY INCIDENTS

SITS SOS shall comply with the relevant provisions of rules and circulars on handling personal data security breaches, including notification to concerned individual or to the National Privacy Commission, where an unauthorized acquisition of sensitive personal information or information that may be used to enable identity fraud has been acquired by an unauthorized person, and is likely to give rise to a real risk of serious harm to the affected data subject. However, it should be noted that under applicable law, not all personal data breaches are notified.

INQUIRIES AND COMPLAINTS

If you have any questions about this Policy, specific privacy statement or our use of personal data, please contact our DPO at cs@sits.ph. SITS SOS shall ensure that all requests, inquiries and concerns are attended within thirty (30) days upon receipt.

CHANGES TO PRIVACY POLICY

Any changes to this Privacy Policy will be posted on this site, along with the information on any material changes. SITS SOS reserves the right to update or modify this Privacy Policy and any specific privacy statement at any time without prior notice. Any modifications will apply only to personal data we collect after posting.

This Privacy Statement is effective on August 1, 2021.