USER DATA AND PRIVACY POLICY
1.
Introduction
1.1.
When you use Upfront, you entrust us with your personal data. We’re committed to keeping that trust.
1.2.
This Data Privacy and User Data Policy (“Privacy Notice”) describe how Upfront, its
respective subsidiaries, affiliates, associated companies and jointly controlled entities
(collectively “Upfront”, “we”, “us” or “our”) collect, use, process, and disclose your
Personal Data through the use of Upfront’s mobile applications and websites
(respectively “Applications” and “Websites”), as well as products, features and other
services, operated by Upfront (collectively, “Services”).
1.3.
This Privacy Notice applies to all our consumers, agents, vendors, suppliers, partners,
contractors and service providers (collectively “you”, “your” or “yours”).
1.4.
This Data Privacy and User Data Policy shall be implemented and monitored in relation
to the prevailing laws of the Philippines as well as established industry standards.
2.
Personal Data
2.1.
Personal Data refers to all types of information whereas personal information is defined
as any information, whether recorded in a material form or not, from which the identity
of an individual is apparent or could certainly identify an individual. This includes but is
not limited to your name, nationality, telephone number, bank and credit card details,
personal interests, email address, your image, government-issued identification
numbers, biometric data, race, date of birth, marital status, religion, health information,
vehicle and insurance information, employment information and financial information.
Upfront generally collects, uses, discloses, or processes your personal information in
accordance with this Privacy Policy, with your consent or in accordance with applicable
law.
2.2.
When you visit our website or access or use our applications and services, we may ask
you to provide us with personal information. If you do not provide the appropriate data,
we may not be able to provide our products and services or answer your queries.
2.3.
We collect and process the personal data when you provide it to us:
2.3.1.
During account creation through our Applications and Websites;
2.3.2.
Generated during the use of our applications and Website or other Services;
2.3.3.
Obtained through third party such as providing us with additional verification and
background information
2.4.
Personal Data that we collect about you:
2.4.1.
Name
2.4.2.
Email Address
2.4.3.
Phone Number
2.4.4.
Address
2.4.5.
Correspondence with us
2.4.6.
IP address or other unique device identifiers
2.4.7.
Usage of our Applications and Website
2.4.8.
Payment and Banking information
2.4.9.
Geolocation
2.4.10.
User profile information, including login details and passwords, profile picture,
saved routes, language preference, beloved drivers’ details, feedback, ratings,
compliments, order details, type of service used and referrer and referee
information of a referral program participated by the User
2.4.11.
Personal data voluntarily entered by the User in free text box when using our Services
2.5.
In case we collect Personal data which is sensitive in nature which may include
Personal Data pertaining to your race, ID information, religious beliefs, background
information, including financial and criminal records, where legally permissible, health
data, disability, marital status and biometric data, as applicable. We only collect
sensitive personal information with your consent and/or in strict compliance with
applicable law. If you need to provide us with any document or information that may
contain such sensitive personal information, please notify us of such sensitive
information prior to providing us with any such documentation or information. You agree
to edit the information in this case.
2.6.
In case you provide Personal Data of other individuals, you represent and warrant that
you have obtained their consent for their Personal Data to be collected, used and
disclosed as set out in this Privacy Notice.
2.7.
We only collect personal data that we reasonably need for effective use of our
Applications and Website. We do not collect personal data that is unnecessary or
excessive.
2.8.
Use of Personal Data:
2.8.1.
Your Personal Data will be used to provide, personalize, maintain and improve our Applications, Websites and Services. This may include the following:
2.8.1.1.
Create, administer and update your account
2.8.1.2.
Engage you to provide you with our Services
2.8.1.3.
Process, manage or verify your eligibility for or application of Services
2.8.1.4.
Verification of your identity when necessary
2.8.1.5.
Validation and confirmation of service and process of payment
2.8.1.6.
Track the progress of the service provided
2.8.1.7.
Perform internal operations necessary to provide our Services, including
troubleshooting software bugs and operational problems, conducting data
analysis, testing and research, monitoring and analyzing usage and activity
trends;
2.8.1.8.
Protect the security or integrity of the Services and any facilities or equipment used to make the Services available
2.8.1.9.
Enable communications between our users and Upfront
2.8.1.10.
Fulfill the services to you as a data processor, where you have provided consent to the data controller (i.e. the organization you had purchased goods or services from, and for whom Upfront is providing services on behalf of) for such services to be rendered.
2.8.2.
We use your personal information to ensure the security of our Service and all users. This includes, but is not limited to, monitoring compliance with our terms of service and policies.
2.8.3.
Personal Data may be used to resolve user support issues.
2.8.4.
To understand and analyze your needs and preferences so that we can protect your personal information, improve and enhance the security of our Services, develop new features, products and services. We may use the personal information we collect for testing, research, analysis, and product development
2.8.5.
We may use the Personal Data we collect for legal purposes, such as to investigate and resolve claims or disputes, detect, prevent, prosecute crime, or as allowed or required by applicable law. We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.
2.9.
Disclosure on Personal Data
2.9.1.
We need to share Personal Data with various parties for an effective use of our Applications and Website.
2.9.2.
We do not disclose personal data for unnecessary or excessive reasons.
2.10.
Retention of Personal Data
2.10.1.
We will retain your personal data for the period necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
2.10.2.
When your Personal Information is no longer needed to use our Services, or there is no longer a legal or business purpose for holding your Personal Information, we may delete, destroy, or anonymize as steps to restrict access to Information. We will prevent this personal information from being used for purposes other than complying with this Privacy Policy or for security, fraud prevention, and detection purposes as required by applicable law.
2.11.
Protection of Personal Data
2.11.1.
We take appropriate legal, organizational and technical measures to ensure that your personal data is protected. This includes measures to protect personal data from loss, unauthorized use or access. We restrict access to your personal data to our employees when necessary. Those who process your personal data are obliged to do so only in an authorized manner and to keep your information confidential.
2.11.1.
However, the transmission of information over the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted via online means. Transmission is therefore at your own risk.
3.
Privacy and Information Pursuant to Google’s Overall Privacy Policy
3.1.
Any data collected or used pursuant to Your use of the application uploaded on Google
Playstore should be subject to Google's Privacy Policy. Additionally, there are some
special cases explained below applicable to data that Google collects in connection with
the Application.
3.2.
When you are using the Application or the Google Play Developer APIs (available at
https://developer.android.com/google/play/developer-api), Google collects certain
"Usage Information." "Usage Information" means information about Your use of the
Application such as Your page visits and data viewed, Your interactions with the
Application’s features and functionality (including those related to the management of
the Developer Account's app(s)), Your actions when using the Google Play Developer
APIs, and Your login email to the Play Console, the IP addresses, and timestamps
associated with these activities. Google will associate this Usage Information with the
Developer Account.
3.3.
Usage Information and other Relevant Data that Google collects may be shared with
the Account Owner and/or Application Developer in order to enable monitoring and
audit actions to prevent potential abuse and misuse of the application.
3.4.
In case any apps are transferred to a new Developer Account, all Usage Information
related to these apps will be associated and transferred with the new Developer
Account and may be shared with the Account Owner of the new Developer Account as
described in Section 3.3.
3.5.
Google will retain the Usage Information as long as its associated Developer Account is
active. Any changes in Your ability to access the Play Console or the status of Your
user login (including its deactivation) will not affect this retention period.
4.
Location Data
4.1.
Location data refers to information related to objects or elements present in a geographic space or horizon. Location data also refers to the coordinates where a person, place, or object is located or found using GPS coordinates and other similar technologies. Upfront generally collects, uses, discloses, or processes your location data in accordance with this Privacy Policy, with your consent or in accordance with applicable law.
4.2.
When you visit our website or access or use our applications and services, we may ask you to provide us with locational information. If you do not provide the appropriate data, we may not be able to provide our products and services or answer your queries.
4.3.
We collect and process the personal data when you provide it to us:
4.3.1.
During account creation through our Applications and Websites;
4.3.2.
Generated during the use of our applications and Website or other Services;
4.3.3.
Obtained through third party such as providing us with additional verification and background information
4.4.
In case you provide Personal Data of other individuals, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Privacy Notice.
4.5.
We only collect locational data that we reasonably need for effective use of our Applications and Website. This data is stored in our system temporarily for as long as we need it in the providing of our services and products.
5.
Cookies
5.1.
Upfront and the third parties we work with may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers, and similar technologies (collectively, "cookies").
5.2.
Upfront may allow third parties to use cookies on their Websites and Applications to collect the same types of personal information for the same purposes as Upfront itself. Third parties may combine the personal information they collect with other personal information about you from other sources. We do not have access to or control over the cookies they use.
5.3.
You have the right to disable, block or turn off cookies. However, please note that rejecting or deleting some cookies may affect the availability, functionality or use of our websites, services or applications.
6.
User’s rights with respect to Personal Data
6.1.
We respect your legal rights to your personal data. We list below your legal rights and the measures we take to protect these rights. Not all data protection laws are the same so not all of these rights apply in all jurisdictions.
6.1.1.
the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
6.1.2.
the right to request that we rectify your personal data if it is inaccurate or incomplete;
6.1.3.
the right to request that we erase, block or anonymize your personal data in certain circumstances except when we are legally entitled to retain it;
6.1.4.
the right to object to, and the right to request that we restrict our processing of your personal data in certain circumstances;
6.1.5.
the right to request us for the history your personal data that we have collected;
6.1.6.
the right to lodge a complaint with the competent authority if you think that any of your rights have been infringed by us.
6.
Changes in the Privacy Notice
6.1.
We may update this Date Privacy and User Data Policy from time to time in response to the changes in law, technology, or business developments. When we update this Privacy Notice, we will take reasonable steps to notify you of the significant changes. Where required by applicable law, we will obtain your consent to any material changes to our Privacy Policy. You can determine when this Privacy Notice was last updated by checking the date displayed.
7.
Changes in the Privacy Notice
7.1.
We may update this Date Privacy and User Data Policy from time to time in response to the changes in law, technology, or business developments. When we update this Privacy Notice, we will take reasonable steps to notify you of the significant changes. Where required by applicable law, we will obtain your consent to any material changes to our Privacy Policy. You can determine when this Privacy Notice was last updated by checking the date displayed.
8.
Contact Us
8.1.
All comments, queries, complaints, data access requests or data correction requests relating to our use of your personal data are welcome and should be addressed to:
cs.upfront@it-americano.com