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
CATEGORIES | EXAMPLES |
---|---|
Personal Identification | Name, gender, civil status, date of birth, government-issued identification |
Contact Information | Address, telephone or mobile numbers, email address |
Financial Data | Bank account data, credit card data |
Job Application Data | Employment history, educational background, résumé and pictures sent with it, compensation and benefits, pictures included in |
Vendor Accreditation Data | Work-related information regarding your company, your ownership and participation |
Account log-in Information | Log-in ID, password or other security codes |
Images, quotes and/or videos from which you may be identified | Pictures uploaded to the ALI Group social media platforms or provided to us, for example, in the context of a webinar or interview |
Any other information that you voluntarily decide to share with the ALI Group | Feedback, opinions, reviews, comments, uploaded files, information provided for our due diligence process |
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:
CATEGORIES | EXAMPLES |
---|---|
Device Information | IP address, hardware model, IMEI number and other unique device identifiers, operating system version |
Location Information | Your location (derived from your IP address, Bluetooth beacons or identifiers, or other location-based products or features technologies) that may be collected when you enable location-based features |
Information about your visit and use of our websites, digital platforms, and mobile apps | Time, duration, manner of use of our products and services, or products and services connected to ours. |
Social media behavior | Tagging, mentioning, or posting photographs of any development project of Ayala Land and its subsidiaries on any social media platform (i.e., Facebook, Twitter, Instagram, LinkedIn, etc.) |
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:
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:
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
When you apply to become a merchant or tenant in any of our properties for lease
When you are a guest or resident in our hotels and resorts
When you are a guest or shopper in our malls
When you use any of our digital platforms, including mobile apps
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
When you apply for employment or become our employee
When you are our shareholder
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:
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:
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:
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.
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.
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
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:
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:
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.