INTRODUCTION

We are delighted that you have shown interest in the services of (hereinafter referred to as "", "we", "us", "our") which are provided via and the services provided through the website and through our software, APIs, or otherwise and mobile website and mobile applications related, linked, or otherwise connected thereto (collectively the "Platform"). Data protection is particularly high priority for . The use of the Platform of is possible without any indication of Personal Data; however, if a Data Subject wants to use special services via our Platform, Processing of Personal Data may become necessary. If the Processing of Personal Data is necessary, and there is no statutory basis for such Processing, we generally obtain Consent from the Data Subject.

The Processing of Personal Data, such as the name, address, email address, or telephone number of a Data Subject must always be in line with the Data Privacy Act of 2012 (DPA), and in accordance with the country-specific data protection regulations applicable to . Utilizing this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the Personal Data we collect, use and process. Furthermore, Data Subjects are informed through this data protection declaration, of the rights to which they are entitled.

has implemented numerous technical and organizational measures to ensure the complete protection of Personal Data processed through this Platform. However, Internet-based data transmissions may, in principle, have security gaps, so absolute protection may not be guaranteed. For this reason, every Data Subject is free to transfer Personal Data to us via alternative means, e.g. by telephone.

DEFINITIONS

The data protection declaration of is based on the terms used by the Filipino legislators for the adoption of the Data Privacy Act of 2012 (DPA). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, among other things, the following terms:

NAME AND ADDRESS OF THE CONTROLLER

Controller for the Data Privacy Act of 2012 (DPA), other data protection laws applicable in the state of Philippines and other provisions related to data protection is:

COOKIES

The Platform of uses cookies. Cookies are text files that are stored in a computer system via an internet browser.

Many internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Platform and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited internet sites and servers to differentiate the individual browser of the Data Subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, can provide the users of this Platform with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our Platform can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our Platform users. The purpose of this recognition is to make it easier for users to utilize our Platform. The Platform user that uses cookies, e.g. does not have to enter access data each time the Platform is accessed, because this is taken over by the Platform, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The Data Subject may, at any time, prevent the setting of cookies through our Platform employing a corresponding setting of the internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an internet browser or other software programs. This is possible in all popular internet browsers. If the Data Subject deactivates the setting of cookies in the internet browser used, not all functions of our Platform may be entirely usable. uses the following cookies.

COLLECTION OF GENERAL DATA AND INFORMATION

The Platform of collects a series of general data and information when a Data Subject or automated system calls up the Platform. This general data and information is stored in the server log files. The general data collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our Platform (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Platform, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system, (8) names, (9) email address, (10) payment method details such as credit card details (11) phone numbers and, (12) any other similar data and information that may be used in the event of attacks on our information technology systems.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

When using these general data and information, does not draw any conclusions about the Data Subject. Rather, this information is needed to (1) deliver the content of our Platform correctly, (2) optimize the content of our Platform as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, (4) for analytics purposes, (5) to facilitate account creation and login process, (6) request feedback (7) as necessary for basic functionality of the Platform and account management (billing our clients) and, (8) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, analyses Anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise and to achieve an optimal level of protection for the Personal Data we process. The Anonymous data of the server log files are stored separately from all Personal Data provided by a Data Subject.

CONTACT POSSIBILITY VIA THE Platform

The Platform of contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address). If a Data Subject contacts the Controller by email or via a contact form, the Personal Data transmitted by the Data Subject are automatically stored. Such Personal Data transmitted on a voluntary basis by a Data Subject to the data Controller are stored for the purpose of Processing or contacting the Data Subject. There is no transfer of this Personal Data to Third-parties.

Security

This Platform ensures that data is encrypted when leaving the Platform. This process involves the converting of information or data into a code to prevent unauthorised access. This Platform follows this process and employs secure methods to ensure the protection of all credit and debit card transactions. Encryption methods such as SSL are utilised to protect customer data when in transit to and from this Platform over a secure communications channel.

Whilst we do everything within our power to ensure that Personal Data is protected at all times from our Platform, we cannot guarantee the security and integrity of the information that has been transmitted to our Platform.

ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA

The data Controller shall process and store the Personal Data of the Data Subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the Filipino legislators or other legislators in laws or regulations to which the Controller is subject.

If the storage purpose is not applicable, or if a storage period prescribed by the Filipino legislators or another competent legislator expires, the Personal Data are routinely blocked or erased in accordance with legal requirements.

RIGHTS OF THE DATA SUBJECT

1. Right of confirmation

   Each Data Subject shall have the right granted by the Filipino legislators to obtain from the Controller the confirmation as to whether or not Personal Data concerning him or her are being processed. If a Data Subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact us or another employee of the Controller.

2. Right of access

   Each Data Subject shall have the right granted by the Filipino legislators to obtain from the Controller free information about his or her Personal Data stored at any time and a copy of this information. Furthermore, the Filipino directives and regulations grant the Data Subject access to the following information: the purposes of the Processing; the categories of Personal Data concerned; the Recipients or categories of Recipients to whom the Personal Data have been or will be disclosed, in particular Recipients in third countries or international organizations; where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the Controller rectification or erasure of Personal Data, or Restriction of Processing of Personal Data concerning the Data Subject, or to object to such Processing; the existence of the right to file a complaint with a supervisory authority; where the Personal Data are not collected from the Data Subject, any available information as to their source; the existence of automated decision-making, including Profiling, referred to in Section 19(2) and 34(a)(1) of Implementing Rules and Regulations of the DPA and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such Processing for the Data Subject.

   Furthermore, the Data Subject shall have a right to obtain information as to whether Personal Data are transferred to a third country or an international organization. Where this is the case, the Data Subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

   If a Data Subject wishes to avail himself of this right of access, he or she may at any time contact us or another employee of the Controller.

3. Right to rectification

   Each Data Subject shall have the right granted by the Filipino legislators to obtain from the Controller without undue delay the rectification of inaccurate Personal Data concerning him or her. Taking into account the purposes of the Processing, the Data Subject shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.

   If a Data Subject wishes to exercise this right to rectification, he or she may, at any time, contact us or another employee of the Controller.

4. Right to erasure (Right to be forgotten)

   Each Data Subject shall have the right granted by the Filipino legislators to obtain from the Controller the erasure of Personal Data concerning him or her without undue delay, and the Controller shall have the obligation to erase Personal Data without undue delay where one of the following grounds applies, as long as the Processing is not necessary:

   The Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed.

   The Data Subject withdraws Consent to which the Processing is based according to Section 12(a) or 13 of the DPA, and where there is no other legal ground for the Processing.

   The Data Subject objects to the Processing in accordance with Section 34(b) of Implementing Rules and Regulations of the DPA, and there are no overriding legitimate grounds for the Processing.

   The Personal Data have been unlawfully processed.

   The Personal Data must be erased for compliance with a legal obligation in the state of Philippines to which the Controller is subject.

   If one of the aforementioned reasons applies, and a Data Subject wishes to request the erasure of Personal Data stored by , he or she may at any time contact us or another employee of the Controller. or another employee shall promptly ensure that the erasure request is complied with immediately.

   Where the Controller has made Personal Data public and is obliged pursuant to Section 34(e) of Implementing Rules and Regulations of the DPA to erase the Personal Data, the Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other Controllers Processing the Personal Data that the Data Subject has requested erasure by such Controllers of any links to, or copy or replication of, those Personal Data, as far as Processing is not required. or another employee will arrange the necessary measures in individual cases.

5. Right of Restriction of Processing

   Each Data Subject shall have the right granted by the Filipino legislators to obtain from the Controller Restriction of Processing where one of the following applies:

   The accuracy of the Personal Data is contested by the Data Subject, for a period enabling the Controller to verify the accuracy of the Personal Data.

   The Processing is unlawful, and the Data Subject opposes the erasure of the Personal Data and requests the restriction of their use instead.

   The Controller no longer needs the Personal Data for the Processing, but they are required by the Data Subject for the establishment, exercise or defense of legal claims.

   The Data Subject has objected to Processing pursuant to Section 34(b) of Implementing Rules and Regulations of the DPA pending the verification whether the legitimate grounds of the controller override those of the Data Subject.

   If one of the conditions as mentioned above is met, and a Data Subject wishes to request the restriction of the Processing of Personal Data stored by , he or she may at any time contact us or another employee of the Controller. or another employee will arrange the restriction of the Processing.

6. Right to data portability

   Each Data Subject shall have the right granted by the Filipino legislators, to receive the Personal Data concerning him or her, which was provided to a Controller, in a structured, commonly used, and machine-readable format. He or she shall have the right to transmit those data to another Controller without hindrance from the Controller to which the Personal Data have been provided. As long as the Processing is based on Consent pursuant to Section 12(a) or 13 of the DPA, or on a contract pursuant to Section 12 of DPA, and the Processing is carried out by automated means, as long as the Processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.

   Furthermore, in exercising his or her right to data portability pursuant to Section 36 of the Implementing Rules and Regulations of the DPA, the Data Subject shall have the right to have Personal Data transmitted directly from one Controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

   In order to assert the right to data portability, the Data Subject may at any time contact or another employee.

7. Right to object

   Each Data Subject shall have the right granted by the Filipino legislators to object, on grounds relating to his or her particular situation, at any time, to Processing of Personal Data concerning him or her, which is based on Section 34(b) of Implementing Rules and Regulations of the DPA. This also applies to Profiling based on these provisions.

   shall no longer process the Personal Data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the Processing which override the interests, rights and freedoms of the Data Subject, or for the establishment, exercise or defense of legal claims.

   If processes Personal Data for direct marketing purposes, the Data Subject shall have the right to object at any time to the Processing of Personal Data concerning him or her for such marketing. This applies to Profiling to the extent that it is related to such direct marketing. If the Data Subject objects to to the Processing for direct marketing purposes, will no longer process the Personal Data for these purposes.

   In addition, the Data Subject may exercise the right, on grounds relating to his or her particular situation, to object to Processing of Personal Data concerning him or her by for scientific or historical research purposes, or for statistical purposes pursuant to National Archives of the Philippines Act of 2007, unless the Processing is necessary for the performance of a task carried out for reasons of public interest.

   In order to exercise the right to object, the Data Subject may directly contact or another employee.

8. Automated individual decision-making, including Profiling

   Each Data Subject shall have the right granted by the Filipino legislators not to be subject to a decision based solely on automated Processing, including Profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the Data Subject and a data Controller, or (2) is not authorized by the law of Philippines to which the Controller is subject and which also lays down suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests, or (3) is not based on the Data Subject’s explicit Consent.

   If the decision (1) is necessary for entering into, or the performance of, a contract between the Data Subject and a data Controller, or (2) it is based on the Data Subject’s explicit Consent, shall implement suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Controller, to express his or her point of view and contest the decision.

   If the Data Subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact or another employee of the Controller.

9. Right to withdraw data protection Consent

   Each Data Subject shall have the right granted by the Filipino legislators to withdraw his or her Consent to the Processing of his or her Personal Data at any time.

   If the Data Subject wishes to exercise the right to withdraw the Consent, he or she may at any time directly contact or another employee of the Controller.

DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF GOOGLE ANALYTICS (WITH ANONYMIZATION FUNCTION)

On this Platform, the Controller has integrated the component of Google Analytics (with the Anonymization function). "Google Analytics" is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics, the Controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the internet connection of the Data Subject is abridged by Google and Anonymized when accessing our Platform from the state of Philippines.

The purpose of the Google Analytics component is to analyses the traffic on our Platform. Google uses the collected data and information, among other things, to evaluate the use of our Platform and to provide online reports, which show the activities on our Platform, and to provide other services concerning the use of our Platform for us.

Google Analytics places a cookie on the information technology system of the Data Subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyses the use of our Platform. With each call-up to one of the individual pages of this Platform, which is operated by the Controller and into which a Google Analytics component was integrated, the internet browser on the information technology system of the Data Subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the Data Subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our Platform by the Data Subject. With each visit to our Platform, such Personal Data, including the IP address of the internet access used by the Data Subject, will be transmitted to Google in the United States of America. This Personal Data are stored by Google in the United States of America. Google may pass this Personal Data collected through the technical procedure to Third-parties.

The Data Subject may, as stated above, prevent the setting of cookies through our Platform at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the Data Subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the Data Subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this Platform, as well as the Processing of this data by Google and the chance to preclude any such. For this purpose, the Data Subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript that any data and information about the visits of Platform may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the Data Subject is later deleted, formatted, or newly installed, then the Data Subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the Data Subject or any other person who is attributable to their sphere of competence or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under https://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

PAYMENT METHOD: DATA PROTECTION PROVISIONS ABOUT THE USE OF MOLLIE AND PAYPAL AS A PAYMENT PROCESSORS

On this Platform, the Controller has integrated components of Mollie and Paypal. Mollie and PayPal are online payment service provider. Payments are processed via so-called Mollie and PayPal accounts, which represent virtual private or business accounts. Mollie and PayPal are also able to process virtual payments through credit cards when a user does not have a Mollie or PayPal account. Mollie and PayPal account are managed via an email address, which is why there are no classic account numbers. Mollie and PayPal make it possible to trigger online payments to Third-parties or to receive payments. Mollie and PayPal also accept trustee functions and offers buyer protection services.

Mollie has appointed a Data Protection Officer (DPO). Among other things, the DPO is responsible for supervising the Processing of Personal Data by Mollie, taking stock of data Processing and advising on technology and security. The DPO is registered at the Dutch Data Protection Authority under registration number FG000763.

The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.

if you believe that Mollie does not adequately guarantee the correct Processing of Personal Data, please send an email to: .

If the Data Subject chooses "Mollie" or "PayPal" as the payment option in the online shop during the ordering process, we automatically transmit the data of the Data Subject to Mollie and PayPal accordingly. By selecting these payment option, the Data Subject agrees to the transfer of Personal Data required for payment processing.

The Personal Data transmitted to Mollie and PayPal is usually first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also requires such Personal Data, which are in connection with the respective order.

The transmission of the data is aimed at payment processing and fraud prevention. The Controller will transfer Personal Data to Mollie or PayPal, in particular, if a legitimate interest in the transmission is given. The Personal Data exchanged between Mollie or PayPal, and the Controller for the Processing of the data will be transmitted by Mollie to economic credit agencies. This transmission is intended for identity and creditworthiness checks.

Mollie or PayPal will, if necessary, pass on Personal Data to affiliates and service providers or subcontractors to the extent that this is necessary to fulfil contractual obligations or for data to be processed in the order.

The Data Subject has the possibility to revoke Consent for the handling of Personal Data at any time from Mollie and PayPal. A revocation shall not have any effect on Personal Data which must be processed, used, or transmitted in accordance with (contractual) payment processing.

The applicable data protection provisions of Mollie and PayPal may be retrieved under https://www.mollie.com/en/privacy and, https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

LEGAL BASIS FOR THE PROCESSING

Section 21(a) Implementing Rules and Regulations of the DPA serves as the legal basis for Processing operations for which we obtain Consent for a specific Processing purpose. If the Processing of Personal Data is necessary for the performance of a contract to which the Data Subject is party, as is the case, for example, when Processing operations are necessary for the supply of goods or to provide any other service, the Processing is based on Section 21(b) Implementing Rules and Regulations of the DPA. The same applies to such Processing operations which are necessary for carrying out pre-contractual measures, for example, in the case of inquiries concerning our services. If we are subject to a legal obligation by which Processing of Personal Data is required, such as for the fulfilment of tax obligations, the Processing is based on Section 21(c) Implementing Rules and Regulations of the DPA. In rare cases, the Processing of Personal Data may be necessary to protect the vital interests of the Data Subject or another natural person. Then the Processing would be based on Section 21(d) Implementing Rules and Regulations of the DPA. Finally, Processing operations could be based on Section 21(g) of Implementing Rules and Regulations of the DPA. This legal basis is used for Processing operations which are not covered by any of the abovementioned legal grounds, if the Processing is necessary for the purposes of the legitimate interests pursued by us or by a Third-party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of Personal Data. Such Processing operations are particularly permissible because they have been specifically mentioned by the Filipino legislators. They considered that a legitimate interest could be assumed if the Data Subject is a client of the Controller (Section 34(b)(2) of Implementing Rules and Regulations of the DPA).

THE LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD-PARTY

Where the Processing of Personal Data is based on Section 21(g) of Implementing Rules and Regulations of the DPA our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

The criteria used to determine the period of storage of Personal Data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract. If the Data Subject requests for termination or terminates his Account, the Personal Data shall be retained only for as long as necessary based on Section 19(d) of Implementing Rules and Regulations of the DPA.

PROVISION OF PERSONAL DATA AS STATUTORY OR CONTRACTUAL REQUIREMENT; REQUIREMENT NECESSARY TO ENTER INTO A CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE SUCH DATA

We clarify that the provision of Personal Data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the Data Subject provides us with Personal Data, which must subsequently be processed by us. The Data Subject is, for example, obliged to provide us with Personal Data when we sign a contract with him or her. The non-provision of the Personal Data would have the consequence that the contract with the Data Subject could not be concluded. Before Personal Data is provided by the Data Subject, the Data Subject must contact us. We will clarify to the Data Subject whether the provision of the Personal Data is required by law, contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the Personal Data and the consequences of non-provision of the Personal Data.