Privacy Policy

Protecting the personal privacy of every customer, vendor, and employee is a crucial part of gaining and keeping your trust in HAIER LECHUANG WUJIE PHILIPPINES INC. and adheres to the provisions of the Data Privacy Act of 2012 and expresses our full cooperation with the National Privacy Commission (NPC). As a global operating organization, we strive to provide a high level of privacy protection across all of our businesses and services.

This Privacy Statement (“Statement”) does not apply to third-party applications, products, services, websites or social media features that may be accessed through links that we may provide on our website or applications (“Apps”). Accessing those links may result in the collection of information about you by a third party. Unless otherwise stated, we do not control or endorse any third-party websites or their privacy practices. We encourage you to review the privacy policies of such third parties before interacting with them.

Your personal data – what is it?

Personal data refers to any information 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. The processing of your personal data is governed by applicable privacy laws.

What roles do we play in processing your data?

We are the data controller. Data controller refers to a person or organization who controls the collection, holding, processing or use of personal information, including a person or organization who instructs another person or organization to collect, hold, process, use, transfer or disclose personal information on his or her behalf.

We know that you care how data about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly.

When are your personal data collected?

Some of your data may, in particular, be collected by us:

· whenever you register as customer and/or use our online services;

· whenever you use our services and products;

· whenever you contact us via the various channels we offer you.

Our collection of personal data

The personal data we collect may include any and all data you provide to us whenever you enter into a contract with us, register an account with us, use our Apps, add information to your existing account, or any information you may give us in any other way. We use the data that you provide for purposes of administering your use of our services, such as communicating with you, responding to your requests, managing your account, customizing your service experience with us, and improving our products and services. In this regard, please be informed that while you may choose to withhold some or all of your personal data from us, such withholding might bar us from providing you full customer service experience, especially for services that require processing of such data.

All the data we collect from you may be stored as log files in our server or as augmented information associated with you or your devices. These log files are used for analysis, research, auditing, and other purposes. Your data is stored in log files until the data is transferred to backup databases or related texts. We routinely back-up a copy of your data to prevent loss of your data in case of a server breakdown or human error. However, all such copies of your data in our backup database will be retained only for as long as our data retention policy permits (see “How long do we keep your personal data?” below), and will in any case be deleted immediately upon your request.

How do we process your personal data?

We comply with our obligations under applicable privacy laws by keeping personal data up to date; by storing and destroying it securely; by collecting and retaining only the necessary data that we need to service you; by protecting personal data from loss, misuse, unauthorized access and disclosure, and by ensuring that appropriate technical measures are in place to protect personal data.

The processing operations we perform on your data cover automated and non-automated means of collecting, recording, organizing, structuring, storing, altering, retrieving, using, transmitting, disseminating or otherwise making available, aligning or combining, restricting, and/or erasing your data.

We use your personal data for the following purposes:

· To design and deliver our services and activities to you;

· To operate our Apps to provide you access to and use of our services;

· To provide services and products requested by you as described when we collect the information;

· To contact you to conduct research about your opinions of current services and products; or of potential new services and products that we may offer in the future;

· To share your contact details with our global affiliates and offices, for the purposes of internal administration and back-office support, to ensure network security, and to prevent fraud;

· To maintain the integrity and safety of our data technology systems, which store and process your personal data;

· To provide anonymous reporting for internal and external customers;

· To provide you with location based personalized services;

· To enforce or defend our policies or contract;

· To detect and investigate data breaches, illegal activities, and fraud.

What is our lawful basis for processing your personal data?

In general, the lawful bases for us to process your personal data is, as applicable, processing based on your consent, as necessary to enter into and perform our contract with you, or as necessary to pursue the legitimate interests of our company or of authorized third parties.

Legitimate interests may include:

· Implementation and operation of a group-wide organizational structure and group-wide information sharing;

· Right to freedom of expression or information, including in the media and the arts;

· Prevention of fraud, misuse of company IT systems, money laundering or any other activities required by the competent authorities;

· Operation of a whistleblowing scheme;

· Physical security, IT and network security;

· Internal investigations; and

· Proposed mergers and acquisitions.

We commit to collect, process, and use your personal data only for the purposes communicated to you. We will not disclose your data to third parties except under the circumstances of data disclosure described in the “Sharing your Personal Data” section below.

Sharing your personal data

Your personal data will be treated as strictly confidential and will be shared only with the categories of data recipients listed below.

We may disclose your personal data to:

· affiliates within our global group of companies;

· authorized employees for the purpose of providing customer-related and information technology related services;

· third party service providers whom we may sub-contract for services mentioned above;

· government and/or government-affiliated institutions, courts, or law enforcement agencies, to comply with obligations under relevant laws and regulations, to protect our interests, enforce or defend our policies or contract, or respond to claims;

Nothing in this Statement shall prevent the disclosure of Personal Information, which are required to be disclosed by law or court order; provided however that if Haier Philippines is so required to disclose any such Personal Information, it shall provide the customer prompt written notice, so that the customer may seek a protective order or other appropriate remedy to prevent or limit such disclosure.

How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary for the given purpose for which your data is processed. Further, we process your data for no longer than your consent is effective. However, we may retain your personal data as required by applicable laws and regulations, or as necessary to assist with any government and judicial investigations, to initiate or defend legal claims, or for the purpose of civil, criminal or administrative proceedings. Absent any justifiable reason to keep your data, the same shall be deleted and disposed of in a secure manner, in accordance to our data protection policy.

Your rights and your personal data

As provided by law, you may object to the processing of your personal data, request for access to your personal information, and/or have it corrected, amended, deleted, or blocked on reasonable grounds. For a complete list of your rights as Data Subject, you may refer to Republic Act 10173 or the “Data Privacy Act of 2012”.

Further processing

If we wish to use your personal data for a new purpose not covered by this Statement, we will provide you with a notice explaining this new use prior to commencing such further processing. In all cases, further processing shall be based on lawful purpose, and whenever necessary and applicable, we will seek your prior consent to such further processing.

Security

We protect your data using technical measures to minimize the risks of misuse, unauthorized access, unauthorized disclosure, loss or theft, and loss of access. Some of the safeguards we use are data encryption, firewalls, and data access authorization controls. We take our data security very seriously. Therefore, the security mechanisms used to protect your data are checked and updated regularly to provide effective protection against abuse.

Despite our best efforts, however, security cannot be absolutely guaranteed against all threats. If you believe that the security of your data has been compromised, or if you would like to know more about the measures we use to protect your data, do not hesitate to contact us.

Contact us.

For questions, comments, suggestions, complaints, or requests, do not hesitate to contact us through our Data Protection Officer:

Mail:

Attention to: DATA PROTECTION OFFICER

HAIER LECHUANG WUJIE PHILIPPINES INC.

Amorsolo St., Brgy. San Lorenzo, Makati City 1223