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INTRODUCTION

Rockwell Land Corporation and its subsidiaries (Rockwell), respect 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 Rockwell 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 our customers 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, the purposes for which we collect and use your data may be:

• To perform functions necessary to deliver the services, goods and other products offered by Rockwell:
  • To conduct due diligence (e.g. to check credit risk and vendor accreditation) prior to the execution of a contract (sale, lease, etc.), as well as collect necessary personal information to facilitate the fulfillment of the terms of the contract thereafter;
  • To respond to customer, investor and/or vendor enquiries, complaints and requests;
  • To provide customer care activities, monitor quality and security, and provide services timely and efficiently;
  • To inform (through telephone call, SMS or email) about project updates, new residential and commercial launches, as well as complimentary, commercial and promotional advertisements;
• To facilitate online transactions and communicate through interactive user platforms for investor/customer/vendor queries (e.g. livechat, etc.)
• To conduct research and analysis (through surveys or polls) in order to improve customer experience/satisfaction and generate statistical insights,
• To comply with legal and regulatory requirements or obligations and perform such other processing or disclosure that may be required under any law or regulation;

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:

• When you want to become a part of our team:
  • To consider and evaluate your suitability for employment and, with a written or expressed consent, retain your personal information for a maximum of 5 years for future job opportunities that may be of interest to you;
  • To communicate with you about your employment application;
  • When hired, to process your data necessary for your employment such as, but not limited to, payroll, benefits application, allowances and refunds processing, tax processing, retirement benefits, and other purposes that demand processing of your personal data (e.g., to execute business transactions directly related and/or incidental to your job, business travels, anniversaries, social activities, emergencies, and so on);
  • While employed, , for your performance evaluation and career development including seminars, trainings, workshops, and compliance monitoring,
  • Upon separation, to process your data for the exit interview and preparation of your final pay

• When you inquire about or acquire a property:
  • on your obligations to Rockwell;
  • To conduct appropriate credit investigation to assess the risk of you defaulting on your obligations to Rockwell;
  • To administer the sale and the turnover of a particular unit which necessarily includes the preparation of all documentation leading to the transfer of title, and perform all financial processes (reservation fees, amortization, handover fees, etc.) as a result of our transaction;
  • To execute contract or provide information/services concerning the trading, brokerage, leasing, management and other incidental operations of real estates;
  • To update our records and keep your contact details and billing address up to date;
  • To provide safety and security to the unit owners, tenants and employees of tenants/unit owners; and,

• When you apply to become a tenant or merchant in any of our properties for lease:
  • To evaluate the interest of a party in a commitment to lease a space;
  • To conduct appropriate credit investigation to assess the risk of you defaulting on your obligations to Rockwell;
  • To prepare lease contract and other documentations as may be required and necessary in the consummation of the contract;
  • To perform all relevant financial transaction such as processing of security deposits, advanced rental payments, monthly rental payments and other incidental charges included in our contract;
  • To provide safety and security to the unit owners, tenants and employees of tenants/unit owners;
  • To communicate any advisories, or changes in the terms and condition related to your lease contract.

• When you are a vendor/supplier, a potential vendor, or a contractor:
  • To conduct the appropriate due diligence checks;
  • To evaluate your proposal including your manpower, technical and operational capacity;
  • To assess the viability of your proposal and process your accreditation;
  • To communicate any decision on such proposal and issue 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.

• When you are a retail customer:
  • To identify and reward customers that meet the requirements for the loyalty program of the Power Plant Mall’s (e.g. VIP program);
  • To grant access to basic services such as free wi-fi in the mall;
  • To process your raffle entry to such promotion. And, subsequently, to inform you should you win the raffle and use your information publicize the same.

• When you shop with us online:
  • To personalize your viewing and/or shopping experience in our websites, managed by third-party service providers, we are using/sending cookies or web beacons are used to store your preferences and settings; enable you to sign-in; and analyze how our websites and online services are performing. Below is the list of websites that processes orders online:
  • http://powerplantcinema.com
  • http://aruga.com.ph
  • https://therockwellist.com
  • https://shop.therockwellist.com

• To create an account online to have access to the following services:
  • To order and reserve online
  • Check the status and view past orders
  • Check your accumulated points in your loyalty card, if applicable
  • To give feedback on the status of your order, reservation and delivery, whichever is applicable.
  • Make changes and secure your account information
  • To receive and evaluate product reviews online.

What type of personal data do we collect?

The common type of data collected by Rockwell includes the following:

• Basic personal information, such as full name, nickname, home addresses/billing address/shipping address, e-mail address, employment information, telephone, other personal contact numbers, username and password;
• Sensitive personal information, such as age, nationality, marital status, gender, health, education and government issued identification document which includes, but not limited to identity (ID) cards, licenses, social security number;
• Employment record, such as educational background, employment history, certifications, trainings attended, resume and income information of your previous jobs; and
• Financial details such as credit history, bank account, credit card, and debit card information you have provided as a result of our transaction.
• CCTV footages in common areas of owned and managed properties.
• Health declaration forms following guidelines imposed by the local and national government, including the Department of Health and Tourism, in detection and prevention of spread of infectious diseases.

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

How we collect, acquire or generate your data?

We collect data when you:

• Submit a job application;
• Submit a proposal and/or business-related documents;
• Fill-out our forms and submit necessary documents;
• Submit information through any form on our digital platforms or contact us through any of our social media accounts;
• Purchase any of our properties, products, or avail of services and promos;
• Respond to surveys, promotions, and other marketing and sales initiatives;
• Provide personal information in relation to inquiries, requests, and complaints
• Subscribe to our newsletter by indicating your email address; and,
• Disclose your personal information through telephone calls, emails, SMS or verbal communication with our authorized representatives.
• Cameras, including CCTV and thermal scanners.

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
• 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. Rockwell’s Privacy Policy does not apply to such other sites or to the use that those entities make of your information. Rockwell 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.

Who 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 Rockwell 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.

Provided further that any requests for CCTV footage or any certification in connection thereto shall be subject to the presentation of a court order.

What is our Privacy Policy regarding children?

Rockwell is very sensitive to privacy issues and it is especially careful in its communications with children. Rockwell 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 Rockwell or other entities that provide technical fulfillment or other services to Rockwell (for example, services intended to improve our services/web sites, 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 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 Rockwell 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 use a secured server behind a firewall, deploying encryption on computing devices and physical security controls.
• We restrict access to personal data only to qualified and authorized personnel who hold your personal data with strict confidentiality.
• Any personal data that you provide in any of our websites, in spite of being managed by third-party service providers for us, is initially processed and stored by Rockwell. Using a secured connection, only authorized Rockwell personnel can then access and download your personal data from the system.
• We reveal only the last four digits of your credit card numbers when confirming an order. However, we transmit the entire credit card number to the appropriate credit card company during order processing.
• It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign-off when finished using a shared computer.

Where and how long do we keep your personal data?

All data are preserved in accordance with the following retention standards:

1. If the data subject has an existing contract and transaction with Rockwell, the information will be retained all throughout the contract period and 10 years after its completion.
2. If the data subject has no existing contract but has existing transaction with Rockwell, the information will be retained during the transaction and 5 years after its fulfillment.
3. If the data subject has no existing contract and transaction with Rockwell, the information will be retained for a period of 2 years.

Personal data are stored in our facilities located in the Philippines and are retained in accordance with the above parameters, 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.

What if there are changes in our Privacy Policy?

Rockwell 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 shall be duly posted in this website and will take effect immediately. Data subjects are encouraged to periodically check for such updates. 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, including the 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 Rockwell, you may get in touch with us through the Contact Us page of our www.e-rockwell.com website or a written letter or email to our Data Protection Officer (DPO).

Our contact details are as follows:
Data Protection Officer
Attorney Ma. Fe Carolyn Go-Pinoy
2nd Floor, 8 Rockwell, Hidalgo Drive
Rockwell Center, Makati City
Email: CarolP@rockwell.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 July 23, 2023.