Last Updated: August 12, 2022 | Last Reviewed: August 12, 2022
Last Updated: August 12, 2022 | Last Reviewed: August 12, 2022
PJ Lhuillier Incorporated (“us”, “we”, “our”, the “Company”) is a corporation duly organized under the laws of the Republic of the Philippines. We provide you (“you”, “your”), through our technology, our third-party licensors, or our service providers, payment and disbursement services (“Services”), and in doing so we process personal data (“Personal Data”) about you – our Clients, their representative/s, or their customers (collectively, “Data Subjects”) – in accordance with the Data Privacy Act of 2012, its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (“Privacy Laws”).
The Personal Data we collect depends on how our Services are used. We may receive Personal Data directly from Data Subjects, such as when they create an account in PeraPal, when they request from us information about our Services via email or through other means of communication. Other times, we collect Personal Data by recording interactions with our Services.
“Personal Data” refers to any data that identifies, or that could reasonably be used to identify, a Data Subject as an individual. We collect Personal Data in different ways. For example, we collect Personal Data when a business registers for an account, or a Customer makes payments or conducts transactions through our Services. We may likewise collect Personal Data from the identification documents our Clients submit to us when we perform our Know-Your- Customer (KYC) and Customer Due Diligence (CDD) vetting of Our clients prior to establishment of our business relationship with them. We may also receive Personal Data from other sources, such as our partners, financial service providers, identity verification services, and publicly available sources. For clarity, Personal Data does not include data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. The Personal Data that We may collect includes:
In using any of our Services, we also collect and gather other Personal Data through a variety of sources. Among the sources for said Personal Data are our technologies that record the use of our Services supported by our website, websites that implement our Services, and the use of our Services generally. Other Personal Data that we may collect include:
A part or the whole of the Services may be performed by third-party licensors and/or service providers such as Xendit.
We use and process Personal Data to: (i) provide the Services; (ii) detect and prevent fraud; (iii) mitigate financial loss or other harm to Clients, their Customers and the Company, and our third-party licensors; (iv) promote, analyze and improve our products, systems, and tools; and (v) complete reports to be submitted to regulatory agencies.
We also use and process Personal Data for the following purposes:
We do not sell or rent Personal Data to marketers or unaffiliated third parties. We share Data with trusted third parties, including:
We implement reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Should You have reason to believe that our processing of Personal Data is no longer secure, please contact us immediately.
We recognize and acknowledge Data Subjects’ rights guaranteed under Philippine’s Privacy Laws:
Please note that if you exercise any of your rights set out above, we may not be in a position to continue to provide the Services to you or perform on any contract we may have with you, and we will not be liable in the event that we do not continue to provide the Services to or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.
It should likewise be underscored that we have a variety of obligations to retain the Personal Data that we process , including to ensure that transactions can be appropriately processed, settled, refunded or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if Clients may have terminated the Services, we will retain certain Personal Data to meet our obligations. There may also be residual Personal Data that will remain, in anonymized format, within our databases and other records, which will not be removed.
Personal Data may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer Personal Data to countries outside of the Philippines, including the United States, Indonesia, and Singapore which may have data protection rules that are different from those of the Data Subject’s country. However, we will take appropriate measures to ensure that any such transfers comply with applicable data protection laws and that your Data remains protected to the standards described in this Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.
We may collect, use, disclose and otherwise process certain Personal Data about customers when acting as the Client’s service provider. Our Clients are responsible for making sure that their customer’s privacy rights are respected, including ensuring appropriate disclosures about third party data collection, use and processing. To the extent that we are acting as a Client’s Personal Information Processor, we will process Personal Data only in accordance with the terms of our agreement with the Client’s and the Client’s lawful instructions.
We may occasionally update this Policy should there be change in the way we process Personal Data consequent upon a change or improvement to any of our Services. If we modify this Policy, we will post the revised copy of it on our website, and we will also revise the “last updated date” stated above. If we make material changes in the way we use Personal Data we will notify you, where applicable, by posting an announcement on our website, by sending an e-mail, or through Instant Messaging Services or SMS. It remains the responsibility of the Data Subjects to periodically review this Policy. Your continued use of the Services after such change has been implemented shall constitute your consent to such changes.
If you have questions, feedback or concerns regarding this Policy, and your privacy please contact: [email protected]