Privacy Policy Statement

ABOITIZ LAND, INC.’S PRIVACY STATEMENT

Aboitiz Land, Inc. (“Company”) respects and values your privacy and the confidentiality of your personal data.

From time to time, it may be necessary for you to provide your personal data in connection with your (i) transactions with the Company, (ii) visits to our website, portals, our offices, sites, and/or events, (iii) use of our mobile applications, or (iv) other direct or indirect dealings with our Company, our officers, employees, agents, or authorized representatives, as a customer, an applicant, or a third party service provider of goods or services.

This Data Privacy Statement (“DPS”) forms part of the Company’s commitment to comply with the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations the (“IRR”), other guidelines and issuances of the National Privacy Commission, as well as our data privacy and protection policies that we have adopted internally. This DPS informs you how we collect, use, store, and process your personal data with us.

COVERAGE OF THE PRIVACY POLICY

The Information We Collect

We may collect and process personal data from you, which includes Personal Information or Sensitive Personal Information, as defined under the DPA and its IRR, relevant to your transactions with the Company (“Personal Data”). Personal Data may include:

1. Identification Data

Your full legal name, sex/gender, date of birth, nationality, civil status, domicile and residence addresses, tax identification numbers and other government-issued identification, contact numbers (mobile and home), office contact details, company or employer name, job position or rank, office address, source of funds, gross annual income, and such other information necessary for us to process your transactions with the Company.

• Transactional Data

Linkable information to your Personal Data such as bank account number, deposits/payments made from your account, their reference numbers, dates and times they were made; information when you contact us through our official channels; and other transactions you may have with us.

• Financial Data

Information about your property, assets, credit history and capacity, which are relevant to your transactions with us.

• Audio-Visual Data

For security purposes and improvement of our services, we process audio and video recordings of your interactions with us, as well as video footages at our offices, sites, or events for surveillance, reporting, or journalistic purposes, subject to limitations imposed by law.

• Sensitive Personal Data

We may require your government-issued identification numbers or cards for verification purposes or any information that is necessary, incidental to a contractual agreement, or in connection with a requested product or service.

• Relevant Individuals

We may collect information about your family members, beneficiaries, attorneys, attorneys-in-fact, shareholders, beneficial owners, partners, committee members, directors, officers, employees, authorized signatories or representatives, and other relevant individuals.

• Regulatory Compliance

We also collect your Personal Data relevant to our statutory or regulatory compliance obligations under laws and regulations, including but not limited to, reports to the Securities and Exchange Commission, Bureau of Internal Revenue, Department of Human Settlements and Urban Development, National Privacy Commission, Anti-Money Laundering Council, local government units, and other pertinent government offices and entities.

In addition, when you visit our websites or use any of our mobile applications, other information that may also constitute Personal Data, such as your browser type, operating system, IP address, domain name, number of times and dates you visited the website or accessed the mobile application, and the amount of time you spent browsing through the website or mobile application, may likewise be collected via cookies and other tracking technologies, such as transparent GIF files. Aggregate Information, or non-personally identifiable and anonymous data, such as how many times you log onto our websites or mobile applications may also be collected.

How we use cookies and tracking technologies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. It allows websites to recognize your computer when you return, enabling it to display personalized settings and other user preferences. It likewise allows websites to respond to you as an individual, such websites and apps can tailor operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

In general, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You will be given the opportunity to accept or reject the use of cookies on our websites in a pop-up box when you first access our website. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Most web browsers, however, automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You may choose not to accept the cookies; however, this may restrict the services that you can access at our websites. Declining cookies may also prevent you from taking full advantage of our websites.

We use traffic log cookies to identify which pages are being visited. This helps us to analyze data about web page traffic and to improve our website in order to tailor it to your needs. We only use this information for statistical analysis purposes after which, the data is removed from the system.

Purpose and use of the information we collect

The Company, when reasonable and necessary, processes your Personal Data to understand your needs and provide you with better services, and in particular for the following purposes:

1. to provide and improve our products and services to you;
2. to provide information and details of our existing and new products and services;
3. to provide value-added services to you;
4. to evaluate and determine proper answers to your inquiries on our products and services;
5. to keep an internal record for confirming, maintaining, or updating our customer records;
6. for customer relationship management purposes, for sending and communicating updates on construction, property management, merchants, leasing, product promotions, events, and other activities in connection with our products and services;
7. for statistical analysis and internal reporting;
8. for identification or verification purposes;
9. to communicate or contact you with regard to your account with us;
10. to satisfy any legal, contractual, or regulatory requirements; and
11. as required under applicable law or regulation or by any decision or order of any court or government agency.

Security and Retention of Personal Information

The Company endeavors to retain your Personal Information only for as long as it is necessary to fulfill the purposes stated above and/or in accordance with legitimate business purposes, or as required under applicable law or regulation or by any decision or order of any court or government agency, except when as otherwise required by lawful orders of authorities, or for the establishment, exercise, or defense of legal claims.

The Information We Disclose

We may share with or disclose your Personal Data to:

1. a credit reference agency where it may be accessed by other financial institutions to assist us in the assessment of your application for credit line with us and for debt tracing and fraud prevention;
2. any of our partner financial institutions providing you credit line facility or any of our partner mortgage brokers who can help connect you with a financial institution who may provide you credit line facility;
3. any of our partners who collaborate with us to provide services to you and provide joint communications that we hope you find of interest;
4. any collection agency, payment center or similar service providers to facilitate the payment of services we have provided you;
5. any of our consultants, advisers or auditors performing services in connection with your account or we have engaged to perform our contractual obligation with your account;
6. any of our agents, contractors, subcontractors performing services in connection with your account;
7. any person to whom we propose to assign or transfer any of our rights and/or duties under our contract with you;
8. any guarantor or person providing security in relation to your obligations under your contract with us;
9. any of our affiliates or subsidiaries for the purposes set out in the DPS in force or for compliance to any law, regulations government requirement, treaty, agreement, policy, or as required by or for the purpose of any court legal process, examination, inquiry, audit, or investigation of any authority. This applies notwithstanding any non-disclosure agreement;
10. any quasi-judicial or judicial tribunal where we have reason to believe that disclosing your Personal Data is necessary for establishing a legal claim or defense, including to obtain legal advice, to exercise the rights of the Company or those of its affiliates or subsidiaries or to institute any legal action, whether under our contract with you or against any third party; or
11. any person as required or permitted by law, rule, or regulation or by any decision or order of any court or government agency.

Any access to Personal Data will be limited to the person who require your Personal Data to perform the functions for which Personal Data has been collected, and as required or allowed by law. We do not sell, trade, or otherwise transfer your Personal Data to third parties. If shared, we will, at your request, provide you with details of the companies with whom we have shared your Personal Data.

Notification of Changes

We recommend that you check this DPS every time you visit our website or mobile applications as we may update this DPS from time to time, by posting the amended notice on this page. Any changes will be effective when posted.

Requests, access, recourse, and questions regarding this Privacy Statement

You are entitled to request that we:

1. provide you with a copy of your Personal Data that we hold and you have the right to be informed of: (a) the source of your Personal Data; (b) the purposes and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entity with whom your Personal Data may be shared;
2. cease processing your Personal Data, in whole or in part, as you direct us, for any purpose, save to the extent it is lawful to do so without consent under the Data Privacy Act of 2012;
3. do not transfer your Personal Data to third parties for the purposes of direct marketing or any other purposes you earlier consented to;
4. correct any errors in your personal Data; and
5. update your personal Data as required.

If you have questions, concerns, or complaints regarding our compliance with the Data Privacy Act of 2012 or if you wish to exercise your rights to access, rectification, object, portability or deletion in instances allowed under the law, we encourage you to first contact us as required by the National Privacy Commission (“NPC”). We will make every reasonable effort to correct, update and respond to your request promptly, unless we require further information from you in order to fulfill your request, and in each case, subject to legal and other permissible considerations. We will also investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal data in accordance with the DPA, its IRR, and other data privacy and protection policies we have put in place. For any complaints that cannot be resolved with us directly, you may bring your concern to the NPC and we commit to cooperate with the NPC and comply with their advice. You may contact our Data Protection Officer via e-mail at aboitizland.dpo@aboitiz.com or by writing to the Data Protection Officer, 21^st Floor NAC Tower, 32^nd Street, Bonifacio Global City, Taguig, Metro Manila, Philippines, for your requests, concerns, questions, and complaints.