Effective Date: June 2021

In this Policy, the terms “we,” “us,” and “ALI group” are references to Ayala Land, Inc. and all its subsidiary companies doing business under the Ayala Land, Inc. name.
The term “you” and its derivatives refer to customers, vendors, partners, employees, associates, and other stakeholders of Ayala Land, Inc.

Background

Ayala Land, Inc. and its subsidiaries are in compliance with the Philippine Data Privacy Act of 2012. The ALI group respects the confidentiality of personal information, and values data privacy rights.

We strive to ensure that all personal information collected from customers, vendors, partners, employees, associates, and other stakeholders are processed in accordance with the general data privacy principles of transparency, legitimate purpose, and proportionality.

Our privacy policy describes how we collect, protect, and manage customer information through our websites, information systems, and processes.

Personal Information We Collect

Personal information refers to data that can be used on its own, or with other information to identify, contact, or locate a single person or an individual in context.

What types of data we collect from you

As part of your dealings with us (e.g., customer, shareholder, business partner, etc.), whether online or offline, we may collect and process your personal information as summarized below.

Personal data you provide us directly

Lastly, when you visit our premises, for security reasons, we might also record data through video or other electronic, digital or wireless surveillance system or device (e.g. CCTV, biometric readers).

Personal data we collect automatically:

When you visit or use our websites or applications, subscribe to our newsletters or otherwise interact with us through our digital channels, in addition to the information you provide to us directly, we may collect information sent to us by your computer, mobile phone or other access device. For example, we may collect:

Information we may collect from other sources

To the extent permitted by applicable law, in addition to our websites, applications and other digital channels, we may also obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms and other third parties.

Information we may aggregate from different sources to your profile

If you have indicated to us that you wish to receive personalized direct marketing communications, we might aggregate data from different sources (both internally and externally) to have a better understanding of your preference and interests, and be able to serve you with more relevant communications. You can always object to these activities by opposing this. In particular, you can always opt-out from receiving marketing-related emails by following the unsubscribe instructions provided in each email.

Ways we collect your personal information

We may collect and store your personal information in a variety of ways:

• When you purchase or avail any of our products, services, promos, activities, and events;
• When you interact with our sales or customer care agents, reservation officers and specialists through email, phone, chat services, or face-to-face meetings;
• When you submit information through manual forms, and online forms on our digital assets (i.e., websites, apps), or contact us through any of our social media accounts (i.e., Facebook, Twitter, Instagram, LinkedIn, etc.);
• When you register, maintain, or use our digital platforms, including our mobile apps;
• When you visit our premises with CCTV surveillance camera that are used for safety and security of our shoppers, guests, employees, and other visitors of our malls, offices, hotels, and resorts;
• When you provide personal information in relation to inquiries, requests, and complaints;
• When you respond to surveys, promotions, and other marketing and sales initiatives;
• When you submit a job application;
• When you are referred to us by third parties or business partners; and
• When you submit your personal information to us for any other reason

Disclosing personal information other than yours

When you disclose to us personal information of another person (e.g., your dependent, spouse, children, and/or parents), you attest that consent has been obtained from that person to disclose and process his/her personal information in accordance with this policy.

If the Personal Information was provided by a minor or one who is not legally capable of entering into contractual transactions without parental or guardian consent, the parent or legal guardian shall be responsible in providing the consent as required under this Data Privacy Policy, and in correcting any information given or informing us that the information should be disregarded or deleted. 

Uses of Personal Information

General uses of your personal information

We may use your personal information for different legitimate reasons and business purposes. Among the general uses are:

• Providing you with product and services that you have requested, including customer support;
• Enhancing your customer experience by delivering product services that match your preference and needs;
• Communicating relevant products and services, advisories, and responses to your queries, requests, and complaints;
• Complying with the requirements of the law and legal proceedings, such as court orders, and legal obligations; preventing imminent harm to the public; and ensuring public security, safety, and order
• Preventing, detecting, and investigating a crime (including fraud and money-laundering);
• Analyzing and managing other commercial risks; and
• Processing of information for statistical, analytical, and research purposes.

Other uses by nature our dealings

Aside from the general uses mentioned above, depending on your dealings with us, we may use your personal information to serve the following purposes:

When you inquire about or purchase property from us

• Conduct of appropriate due diligence checks;
• Registering your inquiry and addressing any follow-up calls;
• Performing financial processes related to the sale, such as the set-up of down payment, amortization, and financing, and performing other actions necessary or desirable in the implementation of our contract
• Managing unit turn-over activities; and
• Communication of advisories and changes in relation to the sale.

When you apply to become a merchant or tenant in any of our properties for lease

• Conducting appropriate due diligence checks for identification and verification;
• Registering and processing your application;
• Preparing lease documents and any other document as may be required;
• Processing of financial transactions (e.g., rental payments), and other actions necessary or desirable in the implementation of our contract; and
• Communicating advisories and changes in the terms and conditions related to your lease contract.

When you are a guest or resident in our hotels and resorts

• Providing the services you request such as to facilitate reservations; conduct identity verification; send confirmations; assist you with meetings, events or celebrations; and confirm details of your accommodation;
• Fulfilling our contractual obligations to you or anyone involved in the process of booking your travel arrangements
• Strengthening our relationship with you before, during, and after your stay through segmentation analysis for statistical, analytics, marketing, and communication purposes
• Personalizing your entire hotel and resort experience with tailor-fit products, services, and offers, including those performed by third parties such as courier and transportation services;
• Providing you with value-added services such as processing for your seamless arrival and departure, resident cards, babysitting, and spa and fitness requirements, and performing all financial processes related to the transaction; and
• Facilitating your application to our partner reward and membership clubs, including contacting you by mail, fax, telephone, or email for marketing purposes.

When you are a guest or shopper in our malls

• Monitoring security, crime, and emergency incidents and situations within mall premises through camera recording and surveillance;
• Determining whether you can avail of any discount or privilege;
• Determining whether you are eligible to participate in any offer, service, event, or activity in our malls;
• Generating data insights from customer feedback and/or mall traffic
• Addressing your queries, requests, and complaints, and conducting any follow-up as may be necessary.

When you use any of our digital platforms, including mobile apps

• Registration, verification, and maintenance your account, as applicable;
• Giving our third-party service providers the necessary information to implement our rewards programs and access to any advanced features of our digital platform, as applicable;
• Assessing your eligibility for certain rewards and programs, and informing you of products, services, events, promotions, and initiatives that may be of interest to you;
• Providing you with personalized customer experience by maintaining your personal profile/dashboard and by showing targeted advertisements that may match your preference and needs; and
• Addressing your queries, requests, feedback, changes to our terms of service, and matters relating to the operation of your account, as applicable.

You may unsubscribe from our offers or marketing materials at any time by clicking the unsubscribe link in the promotional emails or by following the steps provided in the promotional text messages.

When you are a vendor, prospective vendor, or contractor

• Conduct of appropriate due diligence checks;
• Evaluation of your proposal and conduct of corresponding background checks;
• Assessing your viability as a vendor and processing your accreditation;
• Communicating to you matters related to our required products and services; and
• Performing other actions necessary or desirable in the implementation of our contract.

When you apply for employment or become our employee

• Conducting appropriate background investigation, reference checks, pre-employment medical examination and interviews;
• Communicating the status of your candidacy;
• Processing of your compensation, allowances, expense reimbursement and monitoring your attendance and leaves;
• Enrolling in our benefit programs which may include health insurance, medical insurance, retirement plan and social security;
• Assisting you in your professional development through performance management, career development, seminars, workshops, and training;
• Making you part of our employee engagement activities and programs, such as events, employee surveys, and incentives and discounts offered subject to approval of management;
• Complying with our obligations under the law as required by government organizations and local government units; and
• Facilitating, upon separation with the company, your exit interview, clearances, and other procedures necessary to process your final pay.

When you are our shareholder

• Managing the administration of the relationship (e.g., identification verification, including identity of your nominated proxy);
• Communicating the company’s performance including products and services as well as changes in polices, terms and conditions through various applicable channels.

Disclosure of Personal Information with Other Parties

Fulfillment of Legitimate and Business Purposes

In fulfillment of the stated purpose/s that you consented to, we may disclose your personal information to the following parties:

• Our employees and officers;
• Professional advisers such as lawyers and auditors;
• Insurers and credit providers;
• Banks, credit card companies and their respective service providers;
• Suppliers or subcontractors; third-party service providers; consultants that have been contracted by Ayala Land to provide financial, technical, architectural, administrative, and support services such as information technology, payroll, accounting, sales administration, procurement, training, background investigation, loyalty engine or rewards program, and other services, such as but not limited to allowing users to have access to and enjoy other features of our digital platforms;
• Any third-party business offering goods and services or sponsor contest or other marketing and promotional programs, where you have provided your consent;
• Members of our group of companies or our subsidiaries and affiliates;
• Our holding company Ayala Corporation and all its subsidiaries and affiliates; and
• Our joint venture and alliance partners.

Legal and statutory compliance

To the extent that we are required to do so by applicable laws, rules, and regulations, we may share your personal information:

• In connection with any ongoing or prospective legal proceeding;
• To the buyer or prospective buyer of any business or asset that we are contemplating to sell;
• To clients and customers availing of our products and services;
• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of such personal information where, in our reasonable opinion, such court or authority would be reasonably and is likely to order the disclosure of such personal information;

Any company/entity with which we share information about you for the above purposes is contractually required to comply with confidentiality standards, undertake to respect any individual’s right to privacy, and comply with the Data Privacy Act. We also require that these organizations use this information only for our purposes, and follow our reasonable directions with respect to the use and protection of this information. This includes organizations which handle or obtain personal information as service providers for Ayala Land.

International Date Transfers 

Cloud Services

Information that we collect may be stored, processed, and transferred between any of the countries which host the cloud services that we utilize, (e.g., Microsoft Office 365, Amazon Web Services, Salesforce),. All cloud service providers have been evaluated for their ability to meet the minimum requirements of the Data Privacy Act of 2012. Their performance in fulfilling these requirements is part of the Vendor Performance Evaluation.

Internet

Personal information that you publish or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by parties other than those mentioned in the section above (“Disclosure of Personal Information with Other Parties” ).

Retention and Disposal of Your Personal Information

We will retain documents (including electronic documents) containing your personal data:

• To the extent that we are required to do so by law;
• To the extent required by or pursuant to our contract; and
• If we believe that the documents may be relevant to any ongoing or prospective legal proceedings in order to establish, exercise, and defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)..

Thereafter, your personal information 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.

Accessing and Updating Your Personal Information

Accessing your personal information

You may instruct us to provide you with any personal information we hold about you, subject to providing us with appropriate evidence of your identity.

• We may withhold personal information that you request to the extent permitted by law.
• You may instruct us at any time not to process your personal information for marketing purposes.
• You will be asked to expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for the same purpose.

Updating your personal information

If the personal information that we hold about you needs to be corrected or updated, Ayala Land shall make all reasonable efforts to ensure that data collected is current, complete and accurate.

• If you need to access, correct and update your personal information, you may send a request to alidataprivacy@ayalaland.com.ph or get in touch with the customer support team of the product or services that you availed.
• As part of our security measures, we will contact you and conduct the necessary verification measures to process your request. Once we have implemented the necessary corrections, we shall then notify you that your request has been processed and completed.

Withdrawal of consent

If you wish to withdraw the consent you’ve given for any or all purposes set out in this policy, you may send your detailed request to alidataprivacy@ayalaland.com.ph. Depending on the nature of the withdrawal of consent, Ayala Land may no longer be in a position to provide products and services to you.

Protecting Your Information

We take precautions to protect your information. When you submit sensitive information via any of our official websites, such information is protected both online and offline.

Protecting Information, you submit online

• Wherever we collect sensitive information (such as credit card data), such information goes through our payment gateway which encrypts and transmits the data to us in a secure way.
• All our critical websites undergo security scanning and penetration testing to reduce their vulnerability to cyber-attacks. While we employ all necessary precautions to safeguard your information, the internet is not 100% secure, so we cannot guarantee that information we collect or store will be protected from unauthorized access and used in a manner that is inconsistent with this privacy policy

We maintain physical, technical, and organizational safeguards to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification. We also implement safeguards such as:

• Wherever we collect sensitive information (e.g., credit card data), such information goes through our payment gateway, which encrypts and transmits the data to us in a secure way.
• All our critical websites undergo security scanning and penetration testing to reduce their vulnerability to cyber-attacks. While we employ all necessary precautions to safeguard your information, the internet is not 100% secure, so we cannot guarantee that information we collect or store will be protected from unauthorized access and used in a manner that is inconsistent with this privacy policy

We maintain physical, technical, and organizational safeguards to protect your personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification.

How we safeguard your personal information

We also implement safeguards such as:

• The use of secured servers behind advanced threat protection appliances, firewalls, encryptions and other security tools;
• Limiting access of your personal information to those who are qualified and authorized to process them. All such persons, wherever they are located, are required to protect the confidentiality and privacy of your personal information in a manner consistent with our privacy policies and practices; and
• Regular security vulnerability and penetration testing of our information system and infrastructure to ensure that your personal information is properly protected.

Third Party Websites

Our websites contain hyperlinks and details of third-party websites. We have no control over and are not responsible for the privacy policies and practices of third parties.

We therefore advise you to study their privacy policies before providing them with any personal information. Once you leave our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

Cookies and Similar Technologies

What is a Cookie?

A cookie is a small file which asks permission to be placed on your computer’s hard drive. If you allow the use of cookies, the file is added to your browser, helping us analyze and identify browsing behavior within our digital assets. Cookies allow web applications to respond to you as an individual. The web application can customize its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.

Why are these cookies used?

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

Overall, 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. We may use your browsing behavior to develop promotional offers, products, and services that we feel are beneficial to you.

What are your options?

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies; however, doing so may prevent you from taking full advantage of the website.

Management and Security

Ayala Land Management is committed to ensure that its Privacy Management Program is constantly reviewed, monitored, and enhanced.

To that end, a Data Protection Officer for Ayala Land and corresponding Compliance Officers of Privacy for our subsidiaries have been appointed to manage and safeguard the handling of your personal information in compliance with the Philippine Data Privacy Act of 2012 (R.A. 1017) and this Policy.

Ayala Land regards personal information breaches very seriously, and has procedures in place to deal with these.

Policy for Camera Surveillance

Ayala Land and its subsidiaries use a CCTV system in capturing images and videos of employees, mall goers, hotel and resort guests, and visitors to monitor security, crime and emergency incidents or situations within the premises. The CCTV data is stored in secure locations, accessed by authorized Ayala Land and subsidiary personnel for legitimate purposes and may be shared with appropriate authority for investigatory purposes.

Individuals identified on the CCTV system have the right to ask for access to footage subject to confirmation and approval of Ayala Land/subsidiary’s management.

Updates to the Policy

As part of our efforts to safeguard and ensure the security and protection of your personal information, Ayala Land amends this privacy policy from time to time. Ayala Land may also update this policy to apply changes due to new laws and regulations affecting the Data Privacy Act, as well as changes in our business operations and environment. Any update will be posted on the Ayala Land corporate website with a date stamp so that you are informed of the latest policy update.

How to Contact Us

For comments, questions, or requests relating to this privacy policy, or complaints in relation to your rights under this privacy policy, you may get in touch with the Ayala Land Group Data Protection Officer by filling up the Ayala Land Group Data Privacy Form.

This privacy notice sets out most of your rights under the data privacy laws. It is important that the personal data we hold about you is accurate and current. We ask that you keep us informed if your personal data changes during your relationship with us.