INTRODUCTION

Updated April 10, 2019

UBX respects and values your right to privacy with utmost importance. We would like to inform you that we are taking the necessary steps for the protection and security of your personal information and of your use of our services. As provided by the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations (“IRR”), and issuances by the National Privacy Commission, the Company guarantees that we are compliant with all the requirements mandated by law, as well as with the generally accepted global data protection standards and regulations. The Company ensures continued protection of your personal information with our organizational, physical, and technical measures for data protection, including policies for evaluation, monitoring, and review of operations and security risks. This Privacy Policy informs you of updates in our corporate policies regarding the collection, use, storage, disclosure, and disposal of personal information we receive and collect from the Company customers, payees, users, and any individual who communicate, raise inquiries and concerns, as well as transact with us through our authorized representatives, company agents, official websites and platforms, and web-based applications and channels. This Privacy Policy shall be subject to changes in our policies and the law. We shall notify you of the changes by posting in our website and other means of communication for your information and reference.

YOUR PRIVACY AND THE LAW

Personal Information refers to any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual. Sensitive Personal Information is any attribute of your personal information that can discriminate, qualify, or classify you such as your age, date of birth, marital status, government-issued identification numbers, account numbers, and financial information. Privileged Information is any and all forms of information which, under the Rules of Court and other pertinent laws, constitute privileged communication (i.e. lawyer-client, priest-confessor, doctor-patient).

Under the Data Privacy Act of 2012, you have the following rights: (1) Right to be informed – you may demand the details as to how your personal information is being processed or have been processed by the Company, including the existence of automated decision-making and profiling systems; (2) Right to access – upon written request, you may demand reasonable access to your personal information, which may include the contents of your processed personal information, the manner of processing, sources where they were obtained, recipients and reason of disclosure; (3) Right to dispute – you may dispute inaccuracy or error in your personal information in the Company systems through our representatives; (4) Right to object – you may suspend, withdraw, and remove your personal information in certain further processing, upon demand, which include your right to opt-out to any commercial communication or advertising purposes from the Company; (5) Right to data erasure – based on reasonable grounds, you have the right to suspend, withdraw or order blocking, removal or destruction of your personal data from the Company’s filing system, without prejudice to the Company’s continuous processing for commercial, operational, legal, and regulatory purposes; (6) Right to secure data portability – you have the right to obtain from the Company your personal information in an electronic or structured format that is commonly used and allows for further use; (7) Right to be indemnified for damages – as data subject, you have every right to be indemnified for any damages sustained due to such violation of your right to privacy through inaccurate, false, unlawfully obtained or unauthorized use of your information; and (8) Right to file a complaint– you may file your complaint or any concerns with our Data Protection Office at 33/F UnionBank Plaza, Meralco Avenue corner Onyx Road, Pasig City, 1600, Metro Manila, Philippines or privacy@ubx.ph and/or with the National Privacy Commission through www.privacy.gov.ph

COLLECTION AND USE OF YOUR PERSONAL INFORMATION

UBX collects and processes your personal information only upon your express consent, which refers to any freely given, specific, informed indication of will, whereby you agree to the collection and processing of your personal, sensitive or privileged information. The Company processes your personal information in accordance with the law, this Privacy Policy, Terms and Conditions, and other legal instruments which you may have entered into with the Company.

When you provide us with personal information by which you can be reasonably identified, you can be assured that your personal information will be used only in accordance with this Privacy Policy and the relevant Terms and Conditions governing your relationship with us. The Company collects your personal information from the following sources: 1) your Personal Information or Registration Form; 2) information we collect about you when you contact us through our authorized representatives via email, mobile applications or services, and other online and mobile platforms; and) information we collect about you from public records and from other available sources authorized to disclose your information.

All the personal information we collect about you may be combined and processed to improve our products, services, and communications with you. The Company ensures that only authorized employees and third party service providers, who have undertaken to satisfy our stringent corporate, legal, information security, and data privacy requirements, are allowed to process your personal information. Through your express consent, you agree that we may disclose your personal information to our third party service providers who perform business operations on our behalf or partners who collaborate with us to provide services to you and business partners that provide joint communications that we hope you find of interest.

By registering, signing in to, or using the Company’s consent forms in our products, services, web platform and applications, you authorize and consent to the processing, sharing and/or transferring by the Company of your Personal Information relating to your accounts with us for specified purposes which in all cases are in compliance with or pursuant to the Company’s legal or contractual obligations:

  1. Third persons, banks, service providers and entities as the Company deems necessary, to enable the Company to service your account/s and to provide all the existing features of your account/s, the Company’s products, services, facilities, and channels, and any future enhancements thereto or to assist the Company in the processing of your data, including its collection, recording, organization, storage, management, protection, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure, or destruction;
  2. Third parties engaged by the Company or by its subsidiaries or affiliates for the purpose of direct or indirect marketing to offer selected products and services which may interest you unless specifically instructed otherwise in writing;
  3. Insurers, Insurance brokers, or providers of deposit or credit protection or protection against all kinds of risks;
  4. Regulatory authorities when such other persons or entities the Company may deem as having authority or right to such disclosure of information as in the case of regulatory agencies, government or otherwise, which have required such disclosure from the Company and when the circumstance so warrant;
  5. Other related and applicable laws and regulations, subject to your right to information under the Data Privacy Act, which legally mandate the Company to obtain and disclose your personal information to government regulatory agencies and consumer reporting or reference agencies, subject to your right to information under the Data Privacy Act.

Your personal information you provided to the Company shall only be used for the purpose of service and product delivery you consented to, subject to the Terms and Conditions you agreed to. With your express consent, you may agree and authorize the Company to share your personal information with private entities subject to mandatory disclosure pursuant to government and public functions. In all instances, we process and/or disclose your personal information in accordance with the Data Privacy Act and its Implementing Rules and Regulations.

DATA STORAGE

It is the policy of the Company that all systems and storage medium or repositories that store customer data shall have completed the appropriate information security, risk, legal compliance, and privacy impact assessments. Your personal information shall only be stored in the Company- managed environment. Physical copies of documents containing your personal information shall be stored in physical vaults in a sealed and secure manner.

DATA ACCESS AND RETRIEVAL

Access refers to a user’s capacity to access or retrieve data stored within a database or other repository. Your personal information can only be accessed and retrieved by authorized personnel of the Company and only pursuant to a legitimate business purpose, in accordance with the consent you have provided us. Remote connectivity to any Company-managed environment is only through Virtual Private Network or Access Gateway technology solutions that will enable us to enforce security controls required to protect your personal information.

DATA RETENTION

Regulation and legitimate company business purpose and policy define the data retention period of your personal information. Pursuant to the Bureau of Internal Revenue Regulation 17-2013, documents pertaining to your billing statements, which indicate taxable transactions shall be preserved for ten (10) years. Further, the Company keeps your personal information as long as it is necessary: a) for the fulfilment of the declared, specified, and legitimate purposes provided above, or when the processing relevant to the purposes has been terminated; b) for the establishment, exercise or defense of legal claims; or c) for legitimate business purposes, which shall be in accordance with the standards of the fintech industry.

DATA DISPOSAL

The Company has established mechanisms for secure disposal of data from the Company’s systems after the data is no longer required by the business for any legitimate purpose and activity. After the defined retention periods, the Company shall dispose your personal information in a secure manner in order to prevent further processing, unauthorized access, or disclosure to any other party.

PERSONAL DATA BREACH MANAGEMENT

Personal Data Breach refers to a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed. A Personal Data Breach shall be subject to notification requirements under the following conditions:

  1. Compromised data involves personal data that may be used to enable identity fraud;
  2. There is reason to believe that the information may have been acquired by an unauthorized person; and
  3. The unauthorized acquisition is likely to give rise to a real risk of serious harm to any affected data subject.

The Company shall notify the National Privacy Commission and affected Customers in case of breach within 72 hours upon knowledge of or reasonable belief by the Company or our third party processor that a personal data breach has occurred. If such event occurs, we shall notify you, through a secure means of communication, of the nature of the breach, your personal information possibly compromised, measures taken to address the breach and reduce negative consequences, contact details of government authorities concerned and our Data Protection Office who can assist you in mitigating the possible ramifications that can compromise you and your right to privacy.

For inquiries, complaints, and other concerns, you may address them in writing to the Company’s Data Protection Officer, Ms. Maria Francesca Montes via privacy@ubx.ph