PAMILYA DATA PRIVACY

PAMILYA recognizes the importance our users place on their personal data and its collection, usage, sharing, and protection. We are dedicated to managing your personal data in compliance with applicable laws whenever you utilize any features, functions on our Platform or Services, interact with us through an external service, application, or our customer service agents, or access our Platform or Services via your computer, mobile device, or any other internet-connected device.

Introduction to this Privacy Notice

Welcome to the Pamilya platform operated by We Lead Comtech Inc (collectively referred to as Pamilya, "we", "us", or "our"). Pamilya is committed to adhering to applicable privacy laws and regulations ("Privacy Laws") and respecting the privacy rights and concerns of all users of our Pamilya website (the "Platform"). The Platform, along with the services we provide as described on it, are collectively referred to as the "Services"."Users" are individuals who register for an account with us to use the Services, including both buyers and sellers (collectively, "Users", "you", or "your").

We understand the importance of the personal data you entrust to us and are dedicated to properly managing, protecting, and processing your personal data. This Privacy Policy ("Privacy Policy" or "Policy") is intended to help you understand how we collect, use, disclose, and/or process the personal data you provide to us or that we possess about you, now or in the future, and to assist you in making informed decisions before providing us with any of your personal data.

• "Personal Data" or "personal data" refers to information, whether accurate or not, that can identify an individual either on its own or when combined with other information accessible to an organization. Common examples of personal data include names, identification numbers, and contact information.
• By using the Services, registering for an account with us, visiting our Platform, or accessing the Services, you acknowledge and agree to the practices, requirements, and policies outlined in this Privacy Policy. You consent to our collection, use, disclosure, and processing of your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM.
• If we make changes to our Privacy Policy, we will notify you, including by posting the updated Privacy Policy on our Platform. We reserve the right to amend this Privacy Policy at any time. To the fullest extent permitted by applicable law, your continued use of the Services or Platform, including placing orders, will signify your acknowledgment and acceptance of the changes made to this Privacy Policy.
• This Policy works in conjunction with other notices, contractual clauses, and consent clauses related to the collection, storage, use, disclosure, and processing of your personal data by us, and is not intended to override those notices or clauses unless explicitly stated otherwise.
• This Policy applies to both buyers and sellers using the Services, except where expressly stated otherwise.

When will Pamilya collect personal data?

We may collect personal data about you in the following circumstances:

• When you register and/or use our Services or Platform, or open an account with us.
• When you submit any form, including but not limited to application forms or other forms related to any of our products and services, whether online or in physical form.
• When you enter into any agreement or provide other documentation or information regarding your interactions with us, or when you use our products and services.
• When you interact with us via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms, and emails, including interactions with our customer service agents.
• When you use our electronic services, interact with us via our application, or use services on our Platform. This includes the use of cookies which we may deploy when you interact with our application or website.
• When you grant permissions on your device to share information with our application or Platform.

• When you link your Pamilya account with your social media or other external account or use other social media features, in accordance with the provider’s policies.
• When you carry out transactions through our Services.
• When you provide us with feedback or complaints.
• When you register for a contest.
• When you submit your personal data to us for any reason.

The above list is not exhaustive and includes common instances when personal data about you may be collected.

What personal data will Pamilya collect?

The personal data that Pamilya may collect includes, but is not limited to:

1. Name

2. Email address

3. Date of birth

4. Billing and/or delivery address

5. Bank account and payment information

6. Cellphone or telephone number

7. Gender

8. Information sent by or associated with the device(s) used to access our Services or Platform

9. Information about your network and the people and accounts you interact with

10. Photographs or audio or video recordings

11. Government-issued identification or other information required for our due diligence, know your customer, identity verification, or fraud prevention purposes

12. Marketing and communications data, such as your preferences in receiving marketing from us and third parties, your communication preferences, and your history of communications with us, our service providers, and other third parties

13. Usage and transaction data, including details about your searches, orders, the advertising and content you interact with on the Platform, and other products and services related to you

14. Location data

15. Mobile applications you have installed

16. Any other information you provide when signing up to use our Services or Platform, and while using our Services or Platform, as well as information related to how you use our Services or Platform

17. Aggregate data on content you engage with

•  You agree not to submit any information to us that is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right, at our sole discretion, to require further documentation to verify the information provided by you.
• If you sign up to be a user of our Platform using your social media account ("Social Media Account”), link your Pamilya account to your Social Media Account, or use any Pamilya social media features, we may access information about you that you have voluntarily provided to your Social Media Account provider in accordance with such providers policies. We will manage and use any such personal data in accordance with this Policy at all times.

• If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing. Note, however, that opting out or withdrawing your consent for us to collect, use, or process your personal data may affect your use of the Services and the Platform. For example, opting out of the collection of location information will disable its location-based features.

What about the collection of other data?

• Like most websites and mobile applications, your device sends information that may include data about you, which gets logged by a web server when you browse our Platform. This typically includes, without limitation, your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type and characteristics of your mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring website (if any), the pages you visit on our website and mobile applications, and the times of visit. It may also include a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. This information is also included in anonymous statistics to help us understand how visitors use our site.
• When you view pages on our website, watch content and advertising, or access other software on our Platform or through the Services, most of the same information is sent to us (including, without limitation, IP address, operating system, etc.). However, instead of page views, your device sends us information on the content, advertisements viewed, and/or software installed by the Services and the Platform, along with the times accessed.

• We, along with our authorized service providers and advertising partners, may use"cookies" or other features to collect or share information related to your use of our Services or Platform. These tools help us improve our Platform and the Services we offer, introduce new services and features, and allow us and our advertising partners to provide more relevant content to you, including through remarketing.
• "Cookies" are identifiers stored on your computer or mobile device that record data about your device, how and when the Services or Platform are used or visited, the number of users, and other activities within our Platform. We may link cookie information to personal data, including items you have selected for purchase and web pages you have viewed. This information helps us keep track of your shopping cart, deliver content specific to your interests, enable our third-party advertising partners to serve advertisements on sites across the internet, conduct data analysis, and monitor usage of the Services.
• You can refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that doing so may limit your ability to use the full functionality of our Platform or the Services.             

How Do We Use Your Personal Information? 

We use and disclose personal data for the purposes described below, in accordance with applicable local laws and, if required, upon obtaining your consent.

Depending on your relationship with us (e.g., buyer, seller, and website visitor) the personaldata we collect from you or via third parties may be used for the following purposes:

a. Facilitating Use of Services:

• To enable your use of the Services or access to the Platform

b. Account Administration:

• To manage the online account you may have set up with us.

c. Analytics, Research, and Business Development:

• To better understand user experiences with the Services and the Platform.
• To improve the layout or content of the Platforms pages and customize them for users.
• To identify visitors on the Platform.
• To conduct surveys and research on user demographics and behavior to enhance our technology (e.g., voice recognition) via machine learning or other means.
• To derive further attributes related to you based on the personal data provided, in order to offer more targeted and relevant information.
• To conduct data analysis, testing, and research, and monitor and analyze usage and activity trends.
• To develop our products and services further.

d. Legal and Operational Purposes:

• To verify your identity for fraud detection purposes.
• To compare and verify information with third parties to ensure accuracy.

• To process complaints, feedback, enforcement actions, and take-down requests related to any content you have uploaded to the Platform.
• To produce statistics and research for internal and statutory reporting and record-keeping requirements.
• To store, host, and back up your personal data for operational, legal, or business purposes.
• To share personal data in connection with any proposed purchase, merger, or acquisition of any part of our business, ensuring compliance with applicable data protection laws.
• To prevent or investigate any actual or suspected violations of our Terms of Use, Privacy Notice, or any other policies, including fraud, unlawful activity, omission, or misconduct related to your use of our Services or any other matter arising from your relationship with us.
• To perform due diligence checks.
• To comply with legal and regulatory requirements, including law enforcement requests or requests by governmental or regulatory authorities having jurisdiction over Pamilya, in connection with any legal proceedings.
• To protect the life, health, or personal safety of Pamilya’s employees, its users, and/or the public.

e. Consent-Based Purposes:

• Any other purpose for which your consent has been obtained, in compliance with our obligations under applicable laws, including to notify you at the time of obtaining your consent.

If you are a buyer and/or have signed in or registered with us, the personal data we collect from you or via third parties may be used for additional purposes, such as:

a. Order Processing:

• To process your product orders (whether sold by us or a third-party seller).
• To deliver the products you have purchased. We may share your personal information with third parties (e.g., logistics partners, relevant regulatory authorities) to facilitate delivery.
• To update you on the delivery status.
• To provide customer support for your orders, including product returns.
• To verify and process payment transactions (e.g., credit card payments, bank transfers, remittances, e-wallet transactions), which may involve sharing payment information with third parties such as payment service providers.

b. Service Provision:

• To display your name, username, or profile on the Platform (e.g., in reviews you post).
• To facilitate the use of mini-apps available on the Platform and purchases made via these mini-apps.
• To respond to your queries, feedback, claims, or disputes, directly or through third-party service providers.
• To display your information on scoreboards on the Platform related to campaigns, mobile games, or other activities.
• To enable other users to identify you (e.g., via "Find my friends" or similar functions) and support the socializing function of the Services (where applicable).
• To assess your application for loan facilities and perform credit risk assessments for financial services and products, such as credit or loan facilities, insurance, or credit cards (where applicable).
• To facilitate the integration of third-party loyalty membership programs with our Platform.

c. Marketing and Advertising:

• To provide you with information you may find useful or have requested.
• To send you marketing or promotional information about products and services on our Platform from us or third-party sellers.
• To conduct marketing and advertising activities.

To use the information you provide, such as user-generated content, for our advertising and marketing campaigns to promote the Platform.

d. Purposes:

• To better understand our buyers.
• To conduct automated decision-making processes in accordance with the above purposes, in compliance with applicable laws, including notifying and obtaining your consent.
• If you are a seller, the personal data we collect from you or via third parties may be used for additional purposes, such as:

a. Service Provision:

• To ship or deliver products you have listed or sold through the Platform, involving third parties (e.g., logistics partners, affiliates) or relevant regulatory authorities.
• To respond to your queries, feedback, claims, or disputes, directly or through third-party service agents.
• To verify your documentation for onboarding as a seller, including testing technologies for faster onboarding.
• To display your name, username, or profile on the Platform.
• To verify and process financial transactions (e.g., credit card payments, bank transfers, remittances, e-wallet transactions), which may involve sharing payment information with third parties such as payment service providers.
• To assess your application for loan facilities and perform credit risk assessments for seller financing and products, including credit or loan facilities, insurance, or credit cards (where applicable).
• To provide ancillary logistics services to protect against failed deliveries or customer returns.
• To facilitate the return of products to you through our logistics partner.

b. Marketing and Advertising:

• To send you marketing or promotional materials about products and services on our Platform or services provided by our affiliates.
• To conduct marketing and advertising activities.

Other Purposes:

• To better understand our sellers.
• To conduct automated decision-making processes in accordance with the above purposes, in compliance with applicable laws, including notifying and obtaining your consent.

How Does Pamilya Protect and Retain Customer Information?

Security Measures

• We employ various security measures to protect your personal data on our systems. Your data is stored behind secured networks and is accessible only to a limited number of employees with special access rights. Despite our efforts, we cannot guarantee absolute security.

Data Retention

• We retain personal data in compliance with Privacy Laws and other applicable regulations. We will destroy or anonymize your personal data when we determine that:

1. The purpose for which the data was collected is no longer being served by its retention;

2. Retention is no longer necessary for legal or business purposes; and

3. No other legitimate interests justify further retention.

If you stop using the Platform or if your access to the Platform and Services is terminated or withdrawn, we may continue to store, use, and disclose your personal data in accordance with this Privacy Policy and our legal obligations. Subject to applicable law, we may securely disposeof your personal data without prior notice to you.

Does Pamilya Disclose the Information It Collects from Its Visitors to Outside Parties?

Use, Processing, Disclosure, and Transfer of Personal Data

• In the course of conducting our business, we may need to utilize, process, disclose, and/or transfer your personal data to various third-party service providers, agents, affiliates, or other third parties. These parties may be located either within or outside of Philippines, and such actions may be undertaken for one or more of the aforementioned purposes. These third parties may process your personal data on our behalf or for their own purposes. We strive to ensure that these third parties, including our affiliates, maintain the security of your personal data and only retain it for as long as necessary for the stated purposes. Examples of such third parties include:

1. Our subsidiaries, affiliates, and related corporations.

2. Buyers or sellers with whom you have interacted on the Platform or in connection with our Services.

3. Other users of our Platform.

4. Contractors, agents, service providers, and other third parties who support our business operations, including mailing houses, logistics service providers, financial services providers, advertising and marketing partners, telecommunication companies, information technology companies, and data centers.

5. Governmental or regulatory authorities with jurisdiction over Pamilya or as permitted by applicable laws.

6. Buyers or other successors in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of Pamilya’s assets.

7. Third parties to whom disclosure is necessary, and who may collect and process your personal data for the stated purposes. 

Sharing of User Information

• We may share user information, including statistical and demographic data, about our users and their use of the Services with advertising partners and third-party suppliers of advertisements, remarketing, and/or other programming.

Legal Grounds for Data Usage

• In compliance with applicable laws, we may use your personal data for various legal grounds, including to fulfill our legal obligations, perform contracts with you, pursue legitimate interests where such interests outweigh any prejudice to your data protection rights, or as necessary in connection with legal claims.

Security Measures

• While we implement reasonable security measures as required by Privacy Laws, it is important to note that absolute security cannot be guaranteed. Instances such as unauthorized disclosure due to hacking or technological malfunctions may occur.

User Obligations

• Users possessing another User’s personal data through the Services agree to comply with all applicable Privacy Laws, allow for the removal of such data upon request, and permit review of collected information by the respective User or Pamilya, as required by applicable laws.

Seller Compliance

• Sellers must adhere to all applicable Privacy Laws regarding buyers' personal data received from Pamilya. They are restricted from using such data except as necessary for transactional purposes, refraining from contacting buyers outside of the Pamilya platform, and are required to employ adequate security measures and promptly report any data breaches or loss of user data to Pamilya's Personal Data Protection Officer.

How to Update Your Personal Data?

• Ensuring the accuracy and completeness of the personal data you furnish to us is crucial for uninterrupted use of the Platform and for us to effectively provide the Services. It is your responsibility to keep us informed of any changes to your personal data or if you believe that the information we have about you is inaccurate, incomplete, misleading, or outdated.
• You have the flexibility to update your personal data at any time by accessing your account on the Platform.
• If your personal data remains essential for the aforementioned purposes, we may take measures to communicate the updates to third parties and our affiliates with whom we've shared your personal data.

How to Access and Correct Your Personal Data?

• You can request details about the personal data weve collected from you or inquire about how it has been utilized, disclosed, stored, or processed by accessing the personal account information setting on our Platform. Likewise, you can request modification of any errors or omissions in your personal data collected in the same manner. To expedite the processing of your request, we may need additional information related to your inquiry. However, we reserve the right, in accordance with applicable law, to decline correction requests deemed troublesome or unreasonable.
• We retain the right, as permitted by relevant data protection laws, to levy a reasonable administrative fee for retrieving your personal data records. Should this apply, we will notify you of the fee before proceeding with your request.

How Long Do We Retain Your Personal Information?

• We will retain your personal data only for the duration mandated or permitted by law or as necessary for the purposes for which it was collected.
• As soon as it is deemed reasonable to assume that retention no longer serves the purposes for which the personal data was collected and is no longer required for any legal or business purpose, we will discontinue retention by securely disposing of the data or rendering it anonymous to no longer be associated with you.

What if You are a Minor?

Pamilya adheres to regulations concerning the sale of products to minors as stipulated by applicable laws and does not intend to offer Services or Platform access to minors. We do not knowingly collect personal data from individuals under the legal age of majority.

Confirmation of Legal Age

• By using our Platform, you affirm that you are of legal age and possess the capacity to comprehend and consent to the terms outlined in this Privacy Notice. If you are a minor, you may only utilize our Platform under the supervision of a parent or legal guardian.

Parental Responsibility

• Parents or legal guardians are advised against permitting minors under their supervision to disclose personal data to Pamilya. In the event that personal data of a minor is shared with Pamilya, you, as the parent or legal guardian, hereby provide consent for the processing of such personal data in accordance with this Privacy Notice and assume responsibility for their actions.

User Responsibility

• We do not accept liability for unauthorized use of the Services on the Platform by yourself, users acting on your behalf, or unauthorized individuals. It is your responsibility to make informed decisions regarding Platform usage and to implement measures to prevent misuse of the Services.

How to Withdraw Your Consent for the Continued Use, Disclosure, Storage, and/or Processing of Personal Data?

Withdrawing Consent

• You can withdraw your consent for the continued use, disclosure, storage, and/or processing of your personal data by contacting us using the details provided below. This is subject to any conditions and/or limitations imposed by applicable laws or regulations.

Consequences of Withdrawal

• Please note that if you withdraw your consent for our use, disclosure, storage, or processing of your personal data for the purposes and in the manner stated above, or exercise your other rights under applicable local laws, we may be unable to continue providing the Services to you or fulfill any contract we have with you. We will not be liable if we cannot continue to provide the Services or fulfill our contract with you as a result. Our legal rights and remedies are expressly reserved in such an event.

Unsubscribing from Marketing Information

• You can unsubscribe from receiving marketing information at any time via our by using the unsubscribe function within the electronic marketing materials.

What information is collected by third parties?

• Within the Platform, there may be links directing to other websites operated by entities such as our business affiliates, merchants, or payment gateways. We do not oversee the privacy practices of these websites operated by third parties. It is recommended that you review the applicable privacy policies of these websites to understand how they manage any information they gather from you.
• Its important to note that although a third party may be affiliated with us, we do not govern these third-party websites, each of which might maintain its own distinct privacy and data collection procedures separate from ours. Consequently, we bear no responsibility or liability for the content, security measures (or lack thereof), and operations of these linked sites. These links are provided solely for your convenience, and you access them at your own discretion. Nevertheless, we strive to uphold the integrity of our Platform and the links embedded within it, and therefore, we appreciate any feedback regarding these linked sites (including if a particular link is dysfunctional).

Questions, Feedback, Concerns, Suggestions or Complaints

If you have any questions or concerns about our privacy practices, we welcome you to contact us by e-mail at dpo.ph@pamilya.com.ph

How Will You Know if this Privacy Notice Changes?

Pamilya may change this Privacy Notice from time to time without prior notice. Revised versions of this Privacy Notice will be posted on this page, together with an updated effective date.

Last updated on May 28, 2024