PRIVACY POLICY

PRIVACY POLICY
To create a wonderful world for our customers, partners, community, and the nation as a whole, Globe Telecom, Inc. and its subsidiaries (collectively "Globe," "we," "us," "our") put you, our customers, first. Because we care for you, we regard your privacy with the utmost importance.
This Privacy Policy outlines our policy in relation to the collection, use, and protection of your Customer Data to provide you with a wonderful customer experience. From time to time, we may update our Privacy Policy to reflect current changes in our policy and the law. When we do so, we will notify you by posting it on our website for your information and reference.

YOUR RIGHTS AS OUR CUSTOMER
Globe recognizes that you should be the ultimate decision-maker on matters that involve your Personal Information. To this end, Globe is mindful of the fundamental right to privacy of every Globe customer under the Data Privacy Act of 2012.

By accepting the Terms and Conditions for the use of Globe products and services, you agree to the collection, processing, use, and sharing of your Personal Information in accordance with this Privacy Policy that will enable us to provide you with your desired Globe products and services.

You have the right to be informed of the Personal Information that we collect, process, use, and share. We can provide you with such Personal Information, provided that such Personal Information does not amount to information deemed confidential or proprietary by Globe, or that your request for Personal Information is not vexatious or unreasonable. You have the right to object or withhold your consent to the collection, processing, use, and sharing of your Personal Information. However, we may be constrained to terminate your Globe product or service as your Personal Information may be required to deliver such Globe product or service. Without your Personal Information, we will be unable to provide you with updates on Globe’s latest offerings; similarly, you will be unable to participate in our events, promotions, or other activities.

You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your Personal Information in our processing systems upon discovery and substantial proof that your Personal Information is no longer necessary for the purpose or purposes for which it was collected, and for such other cases provided in the Data Privacy Act of 2012.

You have the right to seek indemnity for damages sustained, if any, due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your Personal Information.

Should you feel that there has been mishandling or misuse of your Personal Information, or that any of your data privacy rights have been violated, you may email us at [email protected].

COLLECTION OF CUSTOMER DATA
As part of our continuing relationship with you, we collect, process, use, and share your Customer Data in accordance with this Privacy Policy and the Terms and Conditions for the use of Globe products and services, as may be applicable. The Customer Data that we collect, process, use, and share are either Personal Information or Non-Personal Information:
1. Personal Information is any information from which the identity of an individual can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual, such as name, gender, date of birth, address, telephone/mobile number, email address, proof of identification, etc. It also includes information about:
  1. The services provided to you, such as call/SMS details, location information, and certain information about your rate plans and features, as required by law; The location of your device whenever it is switched on, if you subscribe to location-based services, subject to coverage limitations; and
  2. Your use of our network, your Internet Protocol addresses, network performance experience, diagnostics, such as signal strength, dropped calls, data failures, and other network performance issues, to help us improve our network and quality of products and services, improve your user experience, determine tailored content, create new products and services, and for other legitimate business purposes.
2. Non-Personal Information is any information that does not identify you individually, and includes statistical or analytical data, and anonymized or aggregated reports.

USE OF CUSTOMER DATA
1. We may share Customer Data with our subsidiaries, affiliates, partners, and third-party service providers as part of business operations and provision of products and services.
2. Without limiting the generality of the foregoing, Customer Data is used to, among others:
  1. Provide you with your subscribed products and services, including customer support;
  2. Help us improve our network and quality of products and services;
  3. Create new products and services;
  4. Enhance your customer experience and determine tailored content to meet your preferences and needs;
  5. Communicate relevant services and/or advisories to you;
  6. Abide by any safety, security, public service or legal requirements and processes;
  7. Process information for statistical, analytical, and research purposes. The use of your information for statistical, analytical, and research purposes enables us to create anonymized and aggregated insight reports that we use to further improve your user experience and to provide new products and services;
  8. Create a customer portrait based on your demographic, and your behavioral, transaction, and interaction data across all products, systems, devices, and/or interaction channels, which we may use as a basis for sending you commercial and promotional alerts, personalized advertisements, financial service offers, and surveys. To be clear, should we need to share data with third parties for advertising and marketing purposes, we only share anonymized and aggregated data, and not your Personal Information;
  9. Compute for a telco score which may be shared with our subsidiaries, affiliates, partners and/or third parties, for various purposes such as, but not limited to, credit scoring, premium subscription offerings, product bundling, consistent with our goal to provide you with new products and relevant offerings to meet your changing needs; and
  10. Comply with the requirements of the law and legal process, such as a court order; to comply with a legal obligation; or to prevent imminent harm to public security, safety, or order, collectively referred to as “Data Use Purpose.”
When required by our Privacy Policy and the law, and before we collect, process, use, or share your Personal Information for any other purpose other than enumerated above, we will ask for your consent. You may avail of our broadcast messages relevant to you through written correspondence, text messaging, internet, or other similar means of communication. You may also change your mind anytime and stop receiving them. When you use our website and electronically communicate with us, depending on your settings, we may use cookies, web beacons, small data text files, or similar technologies to identify your device and record your preferences, with your consent. The completeness and accuracy of your Personal Information help us improve our products and services. Thus, we encourage you to update your Personal Information from time to time.

We outsource or contract the processing of Customer Data to third parties, such as but not limited to, vendors, service providers, partners, or other telecommunications operators, to fulfill any of the above purposes. They are only authorized to use Customer Data for such contracted purposes. They may have access to Customer Data for a limited time under reasonable contractual and technical safeguards to limit their use of such Customer Data. We require them to protect Customer Data consistent with our Privacy Policy.

During roaming or when availing of services offered by foreign service providers through our network, the storage, treatment, and transfer of your Personal Information may be subject to regulations different from Philippine regulations.

PROTECTION OF PERSONAL INFORMATION
We respect your privacy. We take paramount care in protecting your Personal Information. As such, we secure and protect your Personal Information with proper safeguards to ensure confidentiality and privacy; prevent loss, theft, or use for unauthorized purposes; and comply with the requirements of the law.

As Information Security threats continue to develop and evolve at such a rapid pace, we make reasonable and appropriate security arrangements and measures that use a variety of physical, electronic, and procedural safeguards to protect Personal Information. Globe runs a state of the art Security Operations Center with a dedicated team and personnel that monitors our network and systems to make sure risks to Globe and your Personal Information are properly managed. We regularly review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to our system and unauthorized alteration, disclosure, or destruction of information we hold.

We only permit your Personal Information to be collected, processed, used, and shared by our authorized employees, contractors, and subcontractors who hold such Personal Information under strict confidentiality and in accordance with their contractual obligations and who have implemented minimum security features against data leakage, unauthorized access, or disclosure. We restrict access to information to Globe employees, contractors, and subcontractors who need to know such information in order to process it for us, who are subject to strict contractual and technical safeguards, and who are accountable if they fail to meet these obligations.

We only give you or your authorized representative access to your Personal Information. We do not provide, sell, or share your Personal Information to anyone unless you have given your express consent. We also do not use nor share your Personal Information with content and/or information providers without your prior request or consent. Personal Information will only be disclosed to third parties in accordance with this Privacy Policy. We keep our records as accurate as possible. If your Personal Information is wrong, we give you ways to update it. Once you have registered as our customer, you may access your account details and correct your Personal Information by contacting Globe Customer Care ((+632) 7730-1000 or 211 using your mobile phone) or your relationship manager, as may be applicable; or by visiting any Globe Store or our website at www.globe.com.ph.

We keep your Personal Information in our business records, as may be applicable, while you are a customer, or as long as it is necessary to fulfill the purpose for which it was collected, or while it is needed by us for business, tax, or legal purposes. When disposing of your Personal Information, we take reasonable measures to ensure that it is done properly and is not accessible to the public.

We are not responsible for information, content, application, product, or service that we do not provide. But because we care for you and protect you, we take measures to fight spam, fraud, or any unauthorized messages that traverse our network. Further, we will not tolerate the use of our network that violates the law, which shall include but not be limited to:
1. Photo or video voyeurism, including the publication or broadcast or transmission through our network of any sexual act or any similar activity without the consent of the person involved and under circumstances in which the person has a reasonable expectation of privacy, is prohibited and unlawful with corresponding penalties under the law.
2. Child pornography is also prohibited and punishable by law and our network shall not be used in any manner for the storage, transmission, or dissemination of materials containing child pornography. We will report any instances of such activity that we become aware of, to the proper authorities as required by law. We shall cooperate with law enforcement agencies to curtail criminality and prevent criminals from wreaking havoc over the internet, which shall include the blocking of certain sites or prevention of access to certain individuals, all in accordance with the stipulations of the law and with respect to legal due process.

HIGH-LEVEL PRIVACY PRINCIPLES
In addition, we only want the happiest customers, so we commit ourselves to abide by Groupe Speciale Mobile Association (GSMA)’s high-level privacy principles based on internationally recognized and accepted principles on privacy and data protection as follows:
1. Openness, Transparency, and Notice
  We are open and honest with you and will ensure that you are provided with clear, prominent, and timely information regarding our data privacy practices. We will provide you with information about the collection of your Personal Information, access, sharing, and further use of your Personal Information, enabling you to make informed decisions about whether to use a mobile application or service.
2. Purpose and Use
  We will limit the access, collection, sharing, disclosure, and further use of your Personal Information to meet legitimate business purposes or to otherwise meet legal obligations.
3. User Choice and Control
  We will give you opportunities to exercise meaningful choice and control over your Personal Information.
4. Data Minimization and Retention
  We will collect, access, and use only the minimum Personal Information necessary to meet legitimate business purposes and to deliver, provision, maintain, or develop applications and services. Personal Information will not be kept for longer than is necessary for those legitimate business purposes or to meet legal obligations, and will subsequently be deleted or rendered anonymous.
5. Respect User Rights
  You will be provided with information about, and an easy means to exercise, your rights over the use of your Personal Information.
6. Security
  Personal Information will be protected, using reasonable safeguards appropriate to the sensitivity of the information.
7. Education
  You will be provided with information about privacy and security issues and ways to manage and protect your privacy.
8. Children
  An application or service that is directed at children will ensure that the collection, access, and use of Personal Information is appropriate in all given circumstances and compatible with applicable law.
9. Accountability and Enforcement
  All responsible persons will be accountable for ensuring that these principles are met.

CONTACT US
Should you wish not to:
1. Have your Personal Information disclosed or processed;
2. Receive marketing alerts and promotional messages from us, our subsidiaries, affiliates, and partners, you may immediately get in touch with us through our website at www.globe.com.ph or by contacting Globe Customer Care ((+632) 7730-1000 or 211 using your mobile phone).
  For any questions or concerns, you may contact our Data Protection Officer as follows:
  
  Data Protection Officer
  Globe Telecom, Inc.
  The Globe Tower
  32nd Street corner 7th Avenue,
  Bonifacio Global City, 1634 Taguig City,
  Metro Manila, Philippines
  Email: [email protected]