INTRODUCTION

Elanvital Enclaves, Incorporated (Elanvital) respects your privacy and recognize the need for appropriate measures to protect and manage your personal data entrusted to us. Our Privacy Policy follows, and is consistent with, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), other issuances of National Privacy Commission (NPC), as well as other relevant laws of the Philippines.

Personal data refers to all types of personal information, sensitive personal information and privileged information. Personal information refers to “any information, whether or not recorded in any form, from which the identity of an individual is apparent or can reasonably and/or directly be ascertained by the entity holding the information, or, when put together with other information, would directly and certainly identify an individual”.

This Privacy Policy pronounces how Elanvital process (how it collects, uses, shares, and keeps) and protect your personal data. It also provides the steps that you can take should you wish for any change in how we use your personal data, or if you want us to stop using your personal data.

Why do we collect your personal data?

To enable us to comply with our corporate policies in relation to data subjects as well as with the requirements under the Data Privacy Act, it is important that we collect, use, store and retain your personal data only as is reasonable and necessary for a declared and specific purpose stated in the pertinent consent forms.

In general, we are using your data for any of the following purposes:

• To perform functions necessary to deliver products offered by Elanvital;

• To provide information about our services which may be of interest to you;

• To respond to specific complaints, inquiries, requests or manage future interactive user function it may be necessary to ask for personal information;

• To provide customer care activities, monitor our quality and security, and provide services timely and efficiently;

• To comply with legal and regulatory requirements or obligations;

• To perform such other processing or disclosure that may be required under law or regulations; and,

• To process and respond to any complaints, inquiries and requests made by you.

Other uses by nature of our transactions

In addition, from the general uses mentioned above, we may use your personal information depending on your transactions with us in any of the following means:

A) When you want to become a part of our team, we collect your information 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

• Provide us with the necessary information to perform related screening and background investigation;

• Communicate with you about your employment application

• Perform information processing such as payroll, benefits application, tax processing of the company’s finance department business programs

• Comply with the company’s obligations under law and as required by government organizations such as DOLE, BIR, HDMF, PhilHHealth and SSS

• Notify you about marketing and sales initiatives such as Elanvital publications, events and promotions

• Provide performance evaluation and career development of employees including training and compliance monitoring

• Consider employee promotions and salary increase rate

• Serve business functions such as approvals, reviewer, signatories

• Comply with the requirements of audit and privacy compliance assessments/review

B) When you are a vendor, a potential vendor, or a contractor, we collect your information to:

• Conduct appropriate due diligence checks;

• Evaluate your proposal including your financial, manpower, technical and operational capacity;

• Assess the practicability of your proposal and process your accreditation;

• Communicate the result of your proposal and to execute a letter of award together with the contract;

• Perform any other action as may be necessary to implement the terms and conditions of our contract;

• Provide us with the necessary information in relation to the broker accreditation;

• Respond to specific complaints, inquiries, requests in relation to your role as a broker;

• 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,

• Comply with the requirements of audit and privacy compliance assessments/review.

C) To enable us to perform processes related with the security monitoring and CCTV Surveillance, it is important that Elanvital collects, uses, stores and retains your personal data when it is reasonable and necessary to:

• Monitor the safety of all personnel inside Elanvital premises

• Perform such other processing or disclosure that may be required under law or regulations

What type of personal data do we collect?

We collect information to provide you with details and information regarding our product, services, and promotions. We process information also to respond to your inquiries or manage future interactive user function. The common type of data collected by Elanvital from you, generally includes the following:

• Basic personal information such as names, addresses, telephone numbers, and other personal contact details;

• Gender, birthplace, citizenship, blood type, height, weight, educational background, employment status and history, government examinations taken and compensation package history;

• Civil status, family background (including parents, sibling/s, spouse, and children’s names, birthdays, birthplace, occupation, and current company), religious belief;

• CTC/Passport number, SSS/GSIS number, Pag-IBIG number, Tax Identification Number (TIN), tax status and other government issued IDs;

• Employment information (self-employed/locally employed/OFW, nature of business, regular/contractual position, years in employment); and

• Dependents (name, birthday, age, relationship)

You are responsible for ensuring that all data, whether personal information, sensitive personal information or privileged information, you submit to Elanvital is accurate, complete and up-to-date.

How do we collect, acquire or generate your data?

We collect data when you:

• Submit a job application;

• Submit a proposal and related business documents;

• Fill-up our forms and disclose your personal information through phone calls, emails, SMS or verbal communication with our authorized representatives

• Purchase or avail of any of our properties, products, services and promos;

• Provide personal information in relation to inquiries, requests, and complaints

Who do we share your personal data with?

As a general rule, we are not allowed to share your data to third party except in limited circumstances as listed below.

By giving your consent, you authorize Elanvital to disclose your personal data to accredited/affiliated third parties or independent/non-affiliated third parties, whether local or foreign in any of the following circumstances:

• As necessary for the proper execution of processes related to the purposes declared in this Privacy Policy.

• The use or disclosure is reasonably necessary, required or authorized by or under law (such as for criminal investigation, as requested by court of law).

This means we might provide your personal data to the following:

• 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;

• All third parties with which we share this personal data are required to use your personal data in a manner that is consistent with this Privacy Policy.

However, these companies may only use such personal data for the purposes disclosed in this Privacy Policy and may not use it for any other purpose.

What is our Privacy Policy regarding children?

Elanvital is very sensitive to privacy issues and it is especially careful in its communications with children. Elanvital would never directly collect personal data from children without the parent’s consent.

Personal data pertaining to children and collected from their parents is used by Elanvital or other entities that provide technical fulfillment or other services to Elanvital (for example, services intended to improve our services, and fulfilling requests or administering promotions). These personal data are not sold.

Meanwhile, we urge parents to regularly monitor and supervise their children’s on-line activities.

How do we protect your personal data?

We take reasonable steps to ensure that the personal data we collect, use or disclose are accurate, complete, and up-to-date. We strictly enforce this Privacy Policy within Elanvital and we have implemented technological, organizational and physical security measures to protect your personal data from loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction. We put in effect safeguards such as the following:

• We keep and protect your personal data using secured servers behind a firewall, deploying encryption on computing devices and physical security controls.

• We restrict access to your personal data only to qualified and authorized personnel who hold your personal data with strict confidentiality.

• Any personal data that you provide is initially processed and stored by Elanvital. Using a secured connection, only authorized Elanvital personnel can then access and download your personal data from the system.

Where and how long do we keep your personal data?

The personal data will be kept in our facilities located in the Philippines after 10 years from date of last transaction or in accordance with industry standards, laws and regulations, unless you request that your personal data be deleted from our systems, databases and hardcopies immediately. Once deleted, your personal data will no longer be searchable or included in anonymous searches and will be completely removed from all the storage location

The Data Privacy Officer may, however, choose not to grant access or correct information based on the request following laws and regulations. He/she will give the individual a written notice that sets out the reason for the refusal.

Do our websites use web analytics?

All our websites engage third-party service providers to analyze the web traffic data for us. This service does use cookies or web beacons.

Cookies are small files that our website puts on your personal computer (PC) to store information about your preferences. Cookies can improve your browsing experience by allowing our website to remember your preferences or letting you avoid signing in each time you visit our website. If you don’t want our website to store cookies on your PC, you can block cookies. But blocking cookies might prevent some pages from displaying correctly, or you might get a message from our website letting you know that you need to allow cookies to view our website.

For you to fully enjoy your visit and browsing experience, only non-identifiable web traffic data are collected and analyzed, including:

• Your internet protocol (IP) address,

• The search terms you used,

• The pages and internal links accessed on our site,

• Demographics (limited to gender and age group),

• The date and time you visited the site, including frequency of visits

• Geolocation,

• Your operating system, and

• Web browser type.

Use the options in your web browser if you do not wish to receive cookies or you wish to set your browser to notify you when you receive cookies. Click on the “Help” section of your browser to learn how to change your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features of this website.

What about the links to third-party websites?

From time to time, we will provide links to third-party web sites, or advertisements which contain links to third-party sites. These links are provided as a service to you and we do not provide any personal data to these websites or advertisers, and therefore, we will not accept responsibility for their privacy practices. These sites are operated by independent entities that have their own privacy policies which you should review as well. JNG’s Privacy Policy does not apply to such other sites or to the use that those entities make of your information. JNG has no control over the content displayed on such sites, nor over the measures, if any, that are taken by such sites to protect the privacy of your information.

What if there are changes in our Privacy Policy?

Elanvital may revise this Privacy Policy as the need arises or when dictated by issuances of the National Privacy Commission or any amendment to the Data Privacy Act. Any change to this Privacy Policy will take effect immediately. Data subjects are encouraged to periodically check for such updates through the Elanvital website. Changes shall not be retroactively applied and will not alter how we handle personal data previously collected without obtaining your consent, unless required by law.

How you can access, correct and update the personal data we have about you?

To exercise your rights which include right to access, modify, erase and object to processing your personal data within a reasonable time after such request or should you have any inquiries, feedbacks on this Privacy Policy, and/or complaints to Elanvital, you may reach us through a written letter or through an email to our Data Protection Officer (DPO). Our contact details are as follows:

Data Protection Officer Level 37 Joy~Nosatlg Center, No. 17 ADB Ave., Ortigas Center Pasig City 1600 Philippines eve.dpo@elanvital.com.ph

You may also lodge a complaint before the National Privacy Commission (NPC). For further details, please refer to NPC’s website: https://privacy.gov.ph/mechanics-for-complaints/.

Any action to a request for correction, erasure and/or objection to process your personal data as it appears in our records is subject to applicable laws and/or the DPA, its IRR and other issuances of NPC.

This Privacy Policy was last amended on October 8, 2020.