Data Privacy Policy Statement and Data Collection Terms and Conditions

1. Introduction

This Policy sets out the commitment of the DDMS Co. to collect and process personal information and sensitive personal information (collectively as personal data) in accordance with the applicable laws and regulations on data privacy, including the Philippine Data Privacy Act of 2012 (DPA) and its implementing rules and regulations (DPA IRR). It explains how DDMS Co. implements that commitment, and the terms and conditions under which DDMS Co. collect and process personal data.

In processing personal data, DDMS Co. adheres to the general privacy principles of transparency, legitimate purpose, and proportionality, and such other relevant principles in the collection, processing, and retention of personal data as required by applicable law.

Also, the DDMS Co. adheres to the Government Website Template Design (GWTD) Guidelines prescribed by the Department of Information and Communications Technology (DICT), which highlights, among others, compliance with the Data Privacy Act of 2012 (Section 2.3.5) and recognizing the importance of improving user experience (Section 3).

This privacy statement applies to [the app] and all its affiliate applications and services that collect or process data and display these terms.

2. Confidentiality under Philippine Law

Information that DDMS Co. receives from clients, whether or not constituting personal data, are generally protected as privileged communications, and covered by its responsibility to its clients to keep that information confidential. DDMS Co. diligently observes this professional obligation. DDMS Co. notes that local law, regulations, and authorities permit disclosure of such information under certain conditions, as when the information has become public and reserves the right to disclose such information when required to do so.

3. Data Collection and Use

In accordance with the DDMS Co.'s mandate to in aiming for a streamlined dental clinic management system, DDMS Co. collects various data and information, including personal information, from various subjects using different systems. Some of this information is provided directly while other information may be provided or collected from other sources as required by its services.

DDMS Co. processes and collects personal information for a lawful purpose connected with its functions and activities of administering Batas Pambansa 79, as amended, and other existing and relevant laws.

DDMS Co. collects personal information directly from clients when they:

  • as a client, downloads DDMS Co. application;
  • register, use or avail of various DDMS Co. application services.

In addition, the client hereby permits DDMS Co. to obtain personal data in other ways. These include, but are not limited to, when a natural or juridical person:

  • enters into an agreement with us, whether or not written, including an employment contract, sponsorship agreement or other contracts to avail of its services or service contract;
  • submits to us any application, form, request, notice, or some other document;
  • becomes an employee, officer, consultant, intern, supplier or service provider;
  • accesses, browses, visits, or uses any of its websites, platforms, social media presence, and other online presence;
  • otherwise provides us with personal data, whether directly or through another person

On the categories of personal data that DDMS Co. collects and processes, the client hereby agrees to provide and permit the company to use the following data which include but is not limited to:

  • name and personal particulars such as contact details, sex, address, birthdate, education;
  • signature;
  • government ID details;
  • employment details;
  • civil status;
  • foreign address and visa;
  • photographs;
  • images via CCTV and other similar recording devices and processes which may be observed when visiting its offices;
  • other information that was included in the DDMS Co. application registration form.

DDMS Co. collect and process personal data to:

  • Perform its duties in accordance with its mandate;
  • Respond to queries, requests and complaints and improve how DDMS Co. interact with its clients;
  • Conduct studies and researches for the purpose of statistics, reviewing, developing and improving its services;
  • Send out regular news from the DDMS Co. through press releases, e-bulletin, among others;
  • Perform other such activities permitted by law or with its clients’ consent.

Recipients of personal data that DDMS Co. collects include ________, hence transfer of data will be cross-border. DDMS Co. may also disclose information, whether intended to be kept confidential or not, upon lawful request by a governmental authority, in response to a court order, or when required by applicable law.

4. Consent and other lawful criteria for collection and processing

Where you, as its client, have provided us with your personal data through any of the interactions mentioned in Section 3, in providing or making available the personal data, you agree and consent to its collecting, using, disclosing, sharing and otherwise processing the personal data for the Purposes, and in the manner and under the terms and conditions, in this Policy.

Applicable law allows us to process your personal data in accordance with other criteria or where the data is not covered by the DPA.

5. Scope and method of collection and processing

DDMS Co. utilizes standard manual and computerized methods and systems to file, store and process personal data. Collection and processing of personal data will be undertaken in accordance with the principles set out in this Policy and as required by law.

6. Data Protection

DDMS Co. fully recognize the value of your personal information particularly as it may include sensitive personal information such as your gender, government-issued IDs, etc. Appropriately, DDMS Co. strives to maintain the confidentiality, integrity and availability of your personal information by employing physical, technological and procedural safeguards. DDMS Co. undertakes reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

DDMS Co. trains its employees to properly handle your information. Whenever DDMS Co. engages with other institutions both local and overseas, DDMS Co. requires them to protect personal information aligned with its own security standards.

7. Data Storage

Your personal information shall be retained for as long as the purpose for which it was collected, and such other purposes that you may have consented to from time to time, remains in effect and until such time as it is no longer required nor necessary to keep your information for any other legal or regulatory purposes.

8. Rights of Data Subjects

Under the DPA, data subjects have the following rights:

  • Right to object - As a data subject, you have the right to indicate your refusal to the collection and processing of your personal data unless the processing is required pursuant to a subpoena, lawful order, or as required by law.
  • Right to access - Upon your request, you may be given access to your personal data that DDMS Co. collect and process insofar as allowed by law.
  • Right to rectification - You have the right to dispute any inaccuracy or error in your personal data and may request us to immediately correct it. Upon your request, and after correction has been made, DDMS Co. will inform any recipient of your personal data of its inaccuracy and the subsequent rectification that was made.

The rights mentioned under this item are not applicable if personal data are processed only for legal and statutory compliance, scientific and statistical research purposes, among others. Your rights as a data subject are also subject to other limitations provided by law and whose exercise is in a reasonable and non-arbitrary manner, and with regard to rights of other parties.

9. Data Breaches

DDMS Co. will comply with the relevant provisions of rules and circulars on handling personal data security breaches, including notification to you or to the National Privacy Commission, where an unauthorized acquisition of sensitive personal information or information that may be used to enable identity fraud has been acquired by an unauthorized person, and is likely to give rise to a real risk of serious harm to the affected data subject. Please note that under applicable law, not all personal data breaches are notifiable

10. Disclosure Pursuant to Judicial or Government Subpoenas, Warrants or Orders

DDMS Co. reserves the right to disclose your personally identifiable information as required by law and when DDMS Co. believe that disclosure is necessary to protect its rights and/or comply with a judicial proceeding, court order, or legal process served on us.

11. Analytics

When you access the application, DDMS Co. may collect non-personal information such as those provided by your device which may include the IP address, operating system, browser type and version, and other machine identifiers. [name of software i.e. google analystics] is being used to track application performance. It gathers non-personal information from the browser whenever the application is visited. This may include the computer's Internet Protocol (IP) address, browser type, browser version, pages visited, date and time of visit, and time spent on these pages, among others. These are reported through aggregated data that in no way will identify an individuals.

12. Cookies and Other Technologies

As described above, DDMS Co. sometimes collects anonymous information from visits to its website(s) to help us provide better service. [THE COMPANY] uses the information that DDMS Co. collects to measure the number of visitors to the different areas of its website(s), and to help us make its website(s) more useful to visitors. This includes analyzing these logs periodically to measure the traffic through its servers, the number of pages visited and the level of demand for pages and topics of interest. The logs may be preserved indefinitely and used at any time and in any way to prevent security breaches and to ensure the integrity of the data on its servers.

DDMS Co. collects the anonymous information DDMS Co. mentioned above through the use of various technologies, one of which is called "cookies". A cookie is an element of data that a website can send to your browser, which may then be stored on your hard drive. The following information is stored in the cookies:

  • IP address
  • Unique ID
  • Session Token

DDMS Co. does not associate the information stored in a visitor's cookie with any other personal data about that visitor. All its employees and customer care officers who have access to personal data and are associated with the processing of that data are bound and obliged to respect the confidentiality of data.

13. Links to External Websites

This website contains links to other websites – visitors are advised to take note of these sites’ respective privacy policy

14. Changes to this Policy

This Privacy Policy is effective as of September 11, 2019, and will remain effective unless there is a revision, which will be effective immediately after being posted on this applicaiton. DDMS Co. reserves the right to modify this privacy statement at any time. Users of this application may also provide feedback to this policy through the contact information provided below.

15. Data Protection Officer

The Data Protection Officer (DPO) is the individual principally responsible for ensuring DDMS Co.'s compliance with applicable laws and regulations for the protection of data privacy and security. The DPO is responsible for the supervision and enforcement of this Policy, and the relevant contact details are as follows:

Data Protection Officer

Name

Address

Email

16. Inquiries

For any inquiry related to this Policy, please contact its Data Protection Officer through the contact details indicated above. If you have received unwanted, unsolicited e-mail sent by DDMS Co. or purporting to be sent via DDMS Co., please forward a copy of that e-mail with your comments to its DPO for review.

All requests, demands or notices which a data subject may send or submit to us under this Policy must be in writing, should be addressed to the Data Protection Officer using the contact details above, and will be deemed duly given (i) on the date of delivery if delivered personally, (ii) on the third Business Day following the date of sending if delivered by a nationally recognized next-day courier service and the service has confirmed delivery, or (iii) if given by electronic mail, when such electronic mail is transmitted to the email address specified above and the appropriate confirmation has been received by the sender via email.

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