OUR LADY OF ETERNAL PEACE, INC.
A MEMORIAL
DATA PRIVACY POLICY
This Privacy Manual is hereby adopted in compliance with Republic Act No. 10173 or the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and other relevant policies, including issuances of the National Privacy Commission. This organization respects and values your data privacy rights, and makes sure that all personal data collected from you are processed in adherence to the general principles of transparency, legitimate purpose, and proportionality.
This Manual shall inform you of our data protection and security measures, and may serve as your guide in exercising your rights under the DPA.
Definition of Terms
“Affiliates” – means Our Lady of Eternal Peace, Inc., including its related companies.
“Data Subject” – refers to an individual whose personal, sensitive personal or privileged information is processed by the organization. It may refer to customers, clients, officers, employees, consultants, suppliers, contractors, and applicants of this organization.
“OLEP” – refer to Our Lady of Eternal Peace, Inc. It shall be interchangeably referred to here as “organization” or “company”.
“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.
“Personal Sensitive Information” – shall refer to those information referred to under the DPA, including but not limited to, an individual’s race, ethnic origin, marital status, age, education
social security numbers, and licenses.
“Processing” refers to any operation or any set of operations performed upon personal information including, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of data.
“Sales representatives” – means broker(s), agents, dealer(s), authorized service partner(s) and/or business partner(s).
Collection of Personal Information
In the course of your dealings with us, we will request that you provide certain personal information to enable us to enter into transactions with you or to deliver the necessary product, services and/or communications in connection with such transactions. These are necessary for our business process execution, including delivery of notices, services and/or products, customer or affiliate and third party vendor relationship management, new product launches and events, planning purposes in connection with future products and services, including promotional events with our sales representatives.
This company collects the personal and sensitive personal information of clients, customers, brokers, suppliers, contractors, employees and applicants. We collect data when you:
- Submit a job application;
- Submit a proposal and related business documents;
- Fill-out our forms and submit necessary documents;
- Submit information through any form on our digital platforms or contact us through any of our social media accounts, as well as from the online retail marketplace.
- Purchase or avail of any of our properties, products, services and promos;
- Respond to surveys, promotions, and other marketing and sales initiatives;
- Provide personal information in relation to inquiries, requests, and complaints;
- Disclose your personal information through phone calls, emails, SMSs or verbal communication with our authorized representatives; and
- Submit identity cards, when you enter into contracts with the company.
What are the information we collect?
The types of information we may collect from you are, among others, the following:
Personal information: your name and nickname, email address, home/residential/business address, telephone number
Sensitive information: your date of birth, age, nationality, civil status, gender, occupation, education, names of beneficiaries and your relationship to them; government issued identification document which includes, but not limited to identity (ID) cards, licenses, social security number; employment record such as educational background, employment history, certifications, trainings attended, resume and income information of your previous jobs.
In relation to interment services, we collect the date of birth, date of death, gender, cause of death, age, civil status, nationality, religious affiliation, last address, identity (ID) card, and nearest of kin of the decedent and your relationship to them.
If you order or purchase flowers, markers or other products and services from or through us, we may collect necessary financial data for those purchases.
If the company orders products or services from suppliers, OLEP may collect financial data for payment of those products or services like bank account numbers.
We also collect information through CCTV or camera visual recordings when you visit our park, building and office premises, or participate in any of our events, and when you avail of our various services.
Other than personal and sensitive information obtained from you directly (as detailed above), we may also obtain your personal information from third parties we deal with or who are connected with you and from such other sources where you have given your consent for the disclosure of information relating to you, and/or where otherwise lawfully permitted.
In addition, when you visit our website, your browser automatically sends us an IP (Internet Protocol) address and certain other information, including the type of browser you use and browser and standard web server log information. We may use this IP address and other information to give you access to the site and otherwise administer the site. However, at this time, we do not send this information to third parties, except as it pertains to Google Analytics.
Google Analytics: We also use Google Analytics on our sites. Google Analytics is a service that anonymously collects website traffic data through cookies. The data, which includes geolocation data, helps us analyze and review how our website visitors use our websites. The data is not sent to any other third parties. If Google is required to by law, it may transmit the anonymous data to a third party.
Visitor Provided Information: In certain parts of the site, we may ask you to provide us with your name or other information so that we can provide you with information you request or take other action indicated in the part of the site where the information is requested. You are under no obligation to provide us with this information, but without it, we may not be able to take the action requested. The site also includes features that allow you and us to communicate by electronic mail, text message, or otherwise.
If you choose to use these features, you will be required to provide us your e-mail address and other personally-identifying information (such as your name, phone number, or street address) we may deem necessary to communicate with you electronically, by text message, or otherwise, or review your request. When you provide any personally identifying information to us, you acknowledge that you are knowingly and voluntarily providing us the information. We will not use such information for marketing purposes, but we may respond to the electronic mail messages you send us, take other action indicated in the part of the site where the information is requested, and use such information for any other business purpose, including sending you subsequent communications concerning this site, or our Company.
You may also give us information about other people, including a spouse, parent, child, other family member, or friends. We only use this information for the specific reason for which you provide it to us.
How We Use the Information Collected?
Personal data you provide will be processed by us for, amongst others, the following purposes as applicable:
- As our customer or client
- To record the ownership, transfers and assignments of memorial lots and/or units;
- To enable us to process and affix the proper name on certificates of ownership issued to clients, transferees, assignees, heirs and successors-in-interest;
- In order for you to enter into the necessary agreement and/or contract in relation to the sale and supply of our services;
- To confirm your identity when you visit the park or one of our chapels, on the basis of our legitimate interests when you visit your loved ones.
- 5. To conduct appropriate credit investigation to assess the risk of you defaulting on your obligations to OLEP;
- To administer the sale of interment lots and prepare all necessary sales documentation as a result of our transaction;
- For the delivery of notices, services or products and the marketing of such services or products to you;
- For our internal record keeping;
- To enable us to send you information by e-mail, telecommunication means (telephone calls or text messages) or social media about products that we think may interest you;
- To establish and better manage any business relationship we have with you;
- To process any communication you send us (for example, answering any queries and dealing with any customer service complaints and feedbacks);
- Post-sales services, such as after-sales service (if any) or customer service related matters; and
- For any other purpose with your consent.
- As an applicant or employee of our organization
- To consider and evaluate your suitability for employment and, with your permission, inform and consider you for future job opportunities that may be of interest to you;
- To communicate with you about your employment application;
- When hired, to process your data necessary for your employment such as, but not limited to, payroll, benefits application, allowances and refunds processing, tax processing, retirement benefits, and other purposes that demand processing of your personal data (e.g. social activities, emergencies, and so on);
- When hired, for your performance evaluation and career development including seminars, trainings, workshops, and compliance monitoring,
- When hired, to process your data necessary to execute business transactions such as preparation and/or approval of business documents and any other functions that are directly related and/or incidental to your job and that will demand processing of your personal data; and,
- Upon separation, to process your data for the exit interview and preparation of final pay.
- As a broker, real-estate agent or sales representative accredited with our organization or applying to be accredited
- To consider and evaluate your suitability for broker accreditation and inform and consider you for future job opportunities that may be of interest to you;
- To communicate with you about your broker accreditation; and
- To inform you about the company’s product, marketing strategies, promotions and other related matters as a broker or agent accredited with us.
- As a vendor, supplier or a contractor
- To conduct appropriate due diligence checks;
- To evaluate your proposal including your manpower, technical and operational capacity;
- To assess the practicability of your proposal and process your accreditation;
- To communicate the result of your proposal and to execute a letter of award together with the contract;
- To perform any other action as may be necessary to implement the terms and conditions of our contract;
- To perform other processes related to or in connection with our business, including those processing or disclosure that may be required under law or regulations; and
- To contact you when we require your services.
Processing of Personal Data (Storage, Retention and Destruction)
This company will ensure that personal data under its custody are protected against any accidental or unlawful destruction, alteration and disclosure as well as against any other unlawful processing. The company will implement appropriate security measures in storing collected personal information, depending on the nature of the information.
We try to make sure that the personally identifying information you provide us remains private. We restrict access to your personal data only to qualified and authorized personnel who hold your personal data with strict confidentiality. We will not sell, rent, trade, or otherwise disclose the personally-identifying information you provide to anyone outside of our company, and its respective affiliates, successors, and service providers, except, and subject to the other provisions in this Policy: (1) in response to a Court Order or other legal or government process in which we believe in good faith that disclosure is legally required by us; (2) to defend us or our property, our officers and staff, including our websites and users, and to enforce our website’s Terms of Service; and (3) if necessary in the unlikely event of an emergency, to protect us, our employees, officers, agents, our website visitors, or the public as required by law, or in a situation in which public authorities are required to deal with an emergency situation.
Please be aware, however, that it may be possible for others to read messages that you send over the Internet, so do not send by e-mail, or post online, any information that you would like to keep confidential.
Disclosure of your personal information
Personal data provided to us will generally be kept confidential but you hereby consent and authorize us to provide or disclose your personal information to the following categories of parties for legitimate business purposes:
- Companies and/or organizations that act as our agents, contractors and/or service providers;
- Our sales representatives for purposes that are related to the purpose for collecting and using your personal information;
- Other parties in respect of whom you have previously given your express consent;
- Our auditors, consultants, accountants, lawyers or other financial or professional advisers;
- Companies and/or organizations, including financial institutions that assist us in processing and/or otherwise fulfilling transactions and providing you with products and/or services that you have requested or subscribed for.
- Our affiliates, subsidiaries, partner companies, organizations, or agencies including their sub-contractors or prospective business partners that act as our service providers and contractors;
- Law enforcement and government agencies;
However, these companies and parties may only use such personal data for the purpose(s) disclosed in this Privacy Policy or as allowed by law, and may not use it for any other purpose.
Disclosure and Sharing
All employees and personnel of the company shall maintain the confidentiality and secrecy of all personal data that come to their knowledge and possession, even after resignation, termination of contract, or other contractual relations. Personal data under the custody of the company shall be disclosed only pursuant to a lawful purpose, and to authorized recipients of such data.
Personal Data Integrity
We will take all reasonable steps to make sure that the personal information collected, used or disclosed is accurate, complete, not misleading and up-to-date.
Personal Data Security
We will take all reasonable steps to protect the personal information we hold from loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction.
We will not keep personal information for longer than is necessary and will take reasonable steps to destroy or permanently de-identify personal information.
Data Transfer and Sharing
Where we consider it necessary or appropriate for the purposes of data storage or processing or providing any service or product on our behalf to you, we may transfer your personal information to another Affiliate within or outside the Philippines, under conditions of confidentiality and similar levels of security safeguards.
Access and Correction
In accordance with the Act, we may on a written request received from you, provide you with access to your personal information and consider a request for correction of that data. In such circumstances, please duly complete the Request Form for Access and/or Correction of Retained Personal data in OLEP’s Possession (“Form”) located here and submit it to:
Data Protection Officer
Our Lady of Eternal Peace, Inc.
Bo. Muzon, City of San Jose Del Monte
Bulacan
Tel: 632-881-6966
We will use reasonable endeavor to respond to your request within 30 days from our receipt of your duly completed Form.
Please note that in certain situations we may have to withhold access to your personal information, for example where we are unable to confirm your identity or where information requested for is of a confidential commercial nature or in the event we receive repeated request for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request.
We reserve the right to charge a reasonable administrative processing fee for retrieving your personal information records. This fee takes into account the time needed for verifying, locating, retrieving, reviewing and copying the information requested as well as any other associated costs and expenses that may arise from conducting such retrieval.
If we do not receive any email from you at [email protected] within fourteen (14) days of this Notice, we shall presume that you have approved of our continued use of your personal information in accordance with this Notice. However, please rest assured that you will be able to terminate this approval at any time.