We are committed to managing your personal data in compliance with the existing data privacy laws in your jurisdiction. This document sets out the procedure to manage complaints on personal data protection.

For more information on how the organization collects, uses, accesses, stores, transfers and handles your personal data, please read sections below.

This Data Privacy and Protection Policy applies when we receive any personal information from you or other third-parties, including but not limited to the following circumstances:

• when you or the organisation you work with request information from us or provide information to us;
• when you or the organisation you work with engages any services from us;
• when you or the organisation you work for provides services to our customers;
• when you apply for any positions or job vacancies with us or when you provide information during any recruitment exercises;
• when you complete any application forms on our Websites;
• when we conduct open source searches on you in connection with our business acceptance or business development processes;
• when you visit our Websites including any online or mobile applications;
• when you are entered into our mailing lists to receive any publications and other marketing information from us; and
• when you visit any of our offices in the region.

We may collect and process personal data directly from:

• you, from our customers or their counterparties and authorised representatives;
• third parties such as regulatory authorities, your employer, other organisations with whom you have dealings, government agencies, credit reporting agencies, recruitment agencies, information or service providers and affiliated companies under Pilmico.

We may collect and process current and historical personal data from you in the ordinary course of the company business which may include, to the extent necessary to respond to your requests, queries and concerns, include basic information such as your name, contact numbers, email address, spouse’s name, number of children, number of employees, area of coverage and assets, monthly sales, monthly expenses and monthly income, house ownership, residence, billing address, years of stay in residence, depositary banks, and other businesses, sensitive personal information such as your age, date of birth, bank account numbers, religion, marital status, date of marriage, profession, tax identification number, government issued identification cards, financial information, and tax returns, among others and other information relevant to customer or applicant surveys and/or offers (collectively, your “Personal Data”).

When you visit our websites or use any of our mobile applications, other information that may also constitute Personal Data, such as your browser type, operating system, IP address, domain name, number of times and dates you visited the website or accessed the mobile application, and the amount of time you spent browsing through the website or mobile application, may be collected via cookies and other tracking technologies, such as transparent GIF files. Aggregate Information, or non-personally identifiable and anonymous data, such as how many times you log onto our websites or mobile applications may also be collected.

Our Websites use cookies. Cookies are  small text files which ask permission to be placed on your computer’s hard drive in order to improve your user experience while using our website. Cookies allow websites to recognize your computer when you return, enabling it to display personalized settings and other user preferences. It also allows websites to respond to you as an individual. The websites and apps can tailor operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being visited. This helps us to analyze data about web page traffic and to improve our website in order to tailor it to your needs. We only use this information for statistical analysis purposes after which, the data is removed from the system.

In general, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You will be given the opportunity to accept or reject the use of cookies on our websites in a pop-up box when you first access our website. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Most web browsers, however, automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You may choose not to accept the cookies, however, this may restrict the services that you can access at our websites. Declining cookies may also prevent you from taking full advantage of our websites.

We may use your Personal Data for us to understand your needs and provide you with a better service, and in particular for the following purposes:

1. to assess your eligibility for a credit line with us;
2. to properly manage and maintain your account, including assessment of your credit status on an on-going basis;
3. for collection of your payment;
4. to meet any requirement in support of your account with us;
5. to expedite evaluation and/or approval of your application as a customer;
6. to keep an internal record for confirming, maintaining or updating our customer records;
7. for customer relationship management purposes, such as updating you on our activities in connection with our services;
8. for statistical analysis and internal reporting;
9.   to establish your identity and qualifications as job applicants; 
10. for identification or verification purposes;
11. to communicate or contact you with regard to your account with us;
12. to satisfy any legal or regulatory requirements; and  
13. as required under applicable law or regulation or by any decision or order of any court or government agency.

We may share your information with our offices across Asia Pacific, branches, subsidiaries and associated companies. You may click on the “Contact Us” page for a link to the geographical locations of our offices. If, in the future, we re-organise or transfer all or part of our business, we may need to transfer your information to new entities or third parties through which our business will be carried out.

We are committed to ensuring that your Personal Data is kept secure. We take reasonable measures to hold information securely in electronic or physical form and have implemented suitable and adequate organizational, physical and technical security measures, policies and procedures intended to reduce the risks of accidental destruction or loss, or the unauthorized disclosure or access to such information which are appropriate and adequate to the nature of the Personal Data we collect. We require our third party data storage providers to comply with appropriate information security industry standards. All partners and staff with access to confidential information are subject to confidentiality obligations.

We remind you that the transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted to our Websites. Any such transmission is at your own risk.

We may retain your Personal Data only for as long as necessary for legitimate business purposes, to comply with laws, regulations, or lawful court order, or to establish or defend a legal action.

We may share with or disclose your Personal Data to:

1. a credit reference agency where it may be accessed by other financial institutions to assist us in the assessment of your application for credit line with us and for debt tracing and fraud prevention;
2. any of our partner financial institution providing you credit line facility;
3. any collection agency, payment center or similar service providers to facilitate the payment of services we have provided you;
4. any of our consultant, adviser or auditor performing services in connection with your account or we have engaged to perform our contractual obligation with your account;
5. any of our agent, contractor, subcontractor performing services in connection with your account;
6. any person to whom we propose to assign or transfer any of our rights and/or duties under our contract with you;
7. any guarantor or person providing security in relation to your obligations under your contract with us;
8. any of our affiliate or subsidiary only for the purposes we have collected your Personal Data;
9. any quasi-judicial or judicial tribunal where we have reason to believe that disclosing your Personal Data is necessary for establishing a legal claim or defense, including to obtain legal advice, to exercise the rights of the Company or those of its affiliates or subsidiaries or to institute any legal action, whether under our contract with you or against any third party; or
10. any person as required or permitted by law, rule or regulation or by any decision or order of any court or government agency.

Any access to Personal Data will be limited to the person who requires your Personal Data to perform the functions for which personal information has been collected, and as required or allowed by law. We do not sell, trade, or otherwise transfer your Personal Data to third parties. If shared, we will, at your request, provide you with details of the companies with whom we have shared your Personal Data.

Please note that your Personal Data may be accessed by third parties and by our offices from countries whose laws provide various levels of protection for personal data which are not always equivalent to the level of protection that may be provided in your own country. When we transfer your information internationally, we will take reasonable steps to ensure that your information is treated securely and the means of transfer provides adequate safeguards.

We recommend that you check this privacy notice every time you visit our Websites as we may update this privacy notice regularly and from time to time, by posting the amended notice on this page. Any changes will be effective when posted. It is your responsibility to review any such amended Privacy Policy.

The privacy laws of some jurisdictions may give you the right to access, amend or erase your Personal Data, or in some circumstances, to restrict or object to the processing of your Personal Data. 

If you would like to request a copy of your data, or would like to take steps to exercise any of your rights, please contact our Data Protection Officers below. We may refuse to provide access and may charge a fee for access if the relevant legislation allows us to do so, in which case, we will provide you with reasons for our decision as required by law. 

Generally, you are entitled to request that we:

1. Provide you with a copy of your Personal Data that we hold and you have the right to be informed of: 

(a) the source of your Personal Data; 

(b) the purposes and methods of processing; 

(c) the data controller’s identity; and 

(d) the entities or categories of entity with whom your Personal Data may be shared;

2. Cease processing your Personal Data, in whole or in part, as you direct us, for any purpose, save to the extent it is lawful to do so without consent;
3. Do not transfer your Personal Data to third parties for the purposes of direct marketing or any other purposes you have not consented to;
4. Correct any errors in your personal Data; and
5. Update your personal Data as required.

If you have questions, concerns or complaints regarding this Data Privacy and Protection Policy, or if you wish to submit a written complaint to us about how we handle your Personal Data, you may contact us through our Data Privacy Officer by way of any of the following channels:

PIPL Data Protection Officer 

Mailing Address: Data Privacy Officer,47 Scotts Road, Goldbell Towers, #16-01/02, Newton, 228233, Singapore
Email Address: goldcoin.dpo@aboitiz.com

Please use the following subject format:  Inquiry on Data Privacy

You may be required to provide Personal Data information for us to be able to assist you with your requests. By providing us with complete information, we will be able to provide you access to, update or correct your personal data as soon as reasonably possible.

For more information on how we handle complaints pertaining to Personal Data, please refer to Personal Data Protection Complaints Procedure.

We will make every reasonable effort to respond to your request within 30 business days subject to legal and other permissible considerations. Should we need more time or information to fulfill your request, we may have an extension of up to 15 business days. During this time, we will communicate with you the reason for the extension. We will also investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal data in accordance with the existing data protection laws and other data privacy and protection policies we have put in place. You may also have the right to submit a complaint to the relevant data protection authorities in your jurisdiction on  any complaint that cannot be resolved with us directly.

All complaints about how an organization manages personal data will be dealt with in accordance with the procedure set out below. Some examples of complaints that might be raised include:

• Unlawful processing of Personal Data;
• Misuse of Personal Data;
• Cause Immediate Harm to Safety or Physical/mental Health
• Unauthorised access or disclose to Personal Data; or
• Loss of Personal Data
• Non Complaint to DNC Provision

The privacy laws of some jurisdictions may give you the right to access, amend or erase your Personal Data, or in some circumstances, to restrict or object to the processing of your Personal Data. 

In the limited circumstances where you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to withdraw such consent at any time.

If you would like to request a copy of your data, or would like to take steps to exercise any of your rights, please contact our Data Protection Officers below. We may refuse to provide access and may charge a fee for access if the relevant legislation allows us to do so, in which case, we will provide you with reasons for our decision as required by law.

If you have any concerns or problems with the way your personal data has been handled, please contact our Data Protection Officer at goldcoin.dpo@aboitiz.com. To assist us in dealing with your complaint, you may be requested for information which may consist of Personal Data and you consent to such disclosure.

If you feel that your complaint has not been resolved satisfactorily by our Data Protection Officers, you may address such complaints through our Whistleblowing Process  within thirty (30) days of receipt of the written notice of the Data Protection Officers informing you of the outcome of the investigations into your complaint.