What is Personal Data
1. Personal Information refers to any data provided about an individual wherein
- i. the identity of an individual is apparent or can be reasonably and directly ascertained; or
- ii. when put together with other information, would directly identify an individual.
2. Sensitive Personal Information means any Personal Information that:
- i. pertains to an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;
- ii. pertains to an individual’s health, education, genetic or sexual life, or to any proceedings in court;
- iii. is issued by government agencies peculiar to an individual, e.g., social security numbers and health records; or
- iv. is specifically established by an executive order or an act of Congress to be kept classified.
3. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, TIN, passport or other identification number, telephone number(s), mobile numbers, mailing address, email address, your company name, job title, network data, credit information and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
Personal Data We Collect
Information you provide to us or any of our business partners. Personal Information you may provide to us through the Service or otherwise includes:
1. Contact Information, such as first and last Name, telephone number(s), mobile numbers, and email address.
2. Account data, such as your username and password that you set to establish an online account with us, and any other information that you add to your account profile.
3. Profile data, such as your company, job title, country and physical addresses, where publicly-available.
4. Payment information, including the dates and amounts of the payments you make to use the Service.
5. Communications that we exchange, including when you contact us with questions, feedback, or otherwise.
6. Marketing data, such as your preferences for receiving communications about our products and services, and details about how you engage with our communications.
Collection of Personal Data
1. We collect Personal Data in the following ways:
- i. When you register to become an Epinoyload Business Partner.
- ii. When you submit an application form or other forms relating to any of our Products and Services
- iii. When you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings and emails;
- iv. When you use some of our services, for example, load wallet replenishment, load top up, bills payment, and airline ticketing;
- v. when you purchase or obtain third party services through us such us purchase of gaming pins and ecoins.
- vi. When you request that we contact you, be included in an email or other mailing list;
- vii. When you respond to our promotions, initiatives or to any request for additional Personal Data;
- viii. When you are contacted by, and respond to, our marketing representatives and customer service officers;
- ix. When we receive references from business partners and third parties.
- x. When we seek information from third parties about you in connection with the Products and Services you have applied for;
- xi. When you subscribe to our newsletters;
- xii. When you submit a job application through our channels which shall ask you to share your personal information; and
- xiii. When you submit your Personal Data to us for any other reasons.
2. Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our sites and other sites and online services. This information may include:
- i. Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, IP address, unique identifiers, the website and app you visited before browsing to our website and our app, and general location information such as city, state or geographic area.
- ii. Online activity data, such as pages you viewed, how long you spent on a page, navigation paths between pages, information about your activity on a page, access times, and duration of access.
- iii. Cookies, dome of our automatic data collection is facilitated by cookies and similar technologies.
3. When you browse our website and app, you generally do so anonymously. Nevertheless, please see the section below on cookies. We do not automatically collect Personal Data unless you provide such information, subscribe to our newsletters, or login with your account credentials.
4. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes in accordance with this Policy.
5. You should check that all Personal Data submitted to us by you is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested. Nevertheless, you have the right to access the Personal Information shared with us and correct your Personal Data as necessary.
Purpose of the Collection, Use, Disclosure, and Processing of your Personal Data
1. Generally, Epinoyload collects, uses, discloses, and processes your Personal Data for the following purposes:
- i. Creating your account in the Epinoyload Platform, logging in to your account and providing the services to you, including the live chat feature in the platform;
- ii. Responding to your queries and requests;
- iii. managing the administrative and business operations of Epinoyload and complying with internal policies and procedures;
- iv. Facilitating transactions involving any of the Companies for the purpose of including but not limited to load wallet replenishment, load top up, purchase of game pins, bills payment, and airline ticketing.
- v. Sending of push notification messages through sms pertaining to the status of the transaction through collected and registered contact information.
- vi. Sending encrypted sms notification messages through the following gateways but not limited to 7670, 21581361, 225651361, 22566003, and other GSM mobile numbers
- vii. Matching any Personal Data held which relates to you for any of the purposes listed herein;
- viii. Resolving complaints and handling requests and inquiries.
- ix. Preventing, detecting and investigating fraudulent transactions;
- x. Providing media announcements and responses;
- xi. Monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
- xii. Legal purposes (including but not limited to obtaining legal advice and dispute resolution);
- xiii. Conducting investigations relating to disputes, billing, suspected illegal activities or fraud;
- xiv. Meeting or complying with any applicable rules, laws, regulations, circulars or guidelines issued by any legal or regulatory bodies which are binding on Epinoyload (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); (I) processing your job application;
- xv. Organizing training and development of employees, and assessing their performance; and
- xvi. Purposes which are reasonably related to the aforesaid.
2. In addition, Epinoyload collects, uses, discloses, and processes your Personal Data for the following purposes:
- i. If you are an Epinoyload Business Partner, or a Customer of Epinoyload’s Business Partner.
- ii. Opening or continuation of accounts and establishing or providing you with the Products and Services you subscribe to (including but not limited to member activation, load wallet replenishment, load top up, purchase of game pins, bills payment, and airline ticketing.);
- iii. Facilitating the continuation or termination of your subscription to our Products and Services (including but not limited to administering subscription arrangements, account maintenance, account closure, processing reactivation of account and customer relationship management);
- iv. Facilitating the daily operation of the Products and Services (including but not limited to billing, customer service, customer verification, technical support, network maintenance and troubleshooting);
- v. Facilitating third party services if purchased, obtained, administered or processed through us;
- vi. Processing of payment instructions, direct debit facilities and/or credit facilities requested by you;
- vii. Credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies);
- viii. Generating internal reports (including but not limited to annual, operational and management reports);
- ix. Processing referral payments, rebates, and commission fees to our external partners;
- x. Administering fee adjustments, refunds and waivers;
- xi. Analyzing your use of our Products and Services so as to help us improve, review, develop and efficiently manage the Products and Services offered to you; and
- xii. Purposes which are reasonably related to the aforesaid.
- xiii. If you are applying for employment, or become a Epinoyload employee:
- xiv. Processing your application, including all pre-employment procedures which require disclosure of your Personal Data;
- xv. Administering your benefits and payroll processing;
- xvi. Organizing training and development programs;
- xvii. Assessing your performance;
- xviii. Purposes which are reasonably related to the aforesaid.
3. Furthermore, where permitted under the Act:
Epinoyload may also collect, use, disclose, and process your Personal Data for the following “Epinoyload Additional Purposes “:
- i. Analytics and tracking, including facilitating the sale of analytical data;
- ii. Conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programs in relation to Epinoyload’s Products and Services, and to improve our service delivery and your customer experience at our touchpoints;
- iii. Providing additional Products and Services and benefits to you, including promotions, loyalty and reward programs from Epinoyload;
- iv. Matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of Products and Services by Epinoyload;
- v. Leads generation and management for marketing Epinoyload’s Products and Services;
- vi. Administering contests, competitions and marketing campaigns, and personalizing your experience at Epinoyload’s touchpoints;
- vii. Communicating to you through advertisements involving details of our Products and Services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling and telemarketing);
- viii. Organizing promotional events and corporate social responsibility projects; and
- ix. Purposes which are reasonably related to the aforesaid.
In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Epinoyload Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by Epinoyload.
- i. Epinoyload may also collect, use, disclose, and process your Personal Data for the following “Preferred Partners Additional Purposes.
- ii. Conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programs with our preferred partners;
- iii. Matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services (including promotions) by our preferred partners;
- iv. Leads generation and management for marketing the products and services offered by our preferred partners;
- v. Administering contests, competitions and marketing campaigns in connection with the products and services offered by our preferred partners;
- vi. Sending you informational, recruitment and other notification messages communicated by our preferred partners;
- vii. Communicating to you through advertisements involving details of the products, services, special offers and rewards offered by our preferred partners, either to our customers generally, or which we or our preferred partners have identified may be of interest to you (including but not limited to upselling, cross selling and telemarketing); and
- viii. Purposes which are reasonably related to the aforesaid.
4. If you have provided your telephone or mobile number/s and have indicated that you consent to receiving marketing or promotional information via your provided telephone or mobile number/s, then from time to time, Epinoyload may contact you using such telephone or mobile number/s (including via voice calls, text, or other means) with information about our Products and Services or those products and services offered by our preferred partners (including discounts and special offers).
5. In relation to particular Products and Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use, disclose, or process your Personal Data. If so, we will collect, use, disclose, and process your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
6. You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.
7. Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with Epinoyload.
8. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Epinoyload may not be in a position to continue to provide its Products and Services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Epinoyload, and your being in breach of your contractual obligations or undertakings. Epinoyload’s legal rights and remedies in such events are expressly reserved.
Disclosure of Personal Data
Epinoyload will take reasonable steps to protect your Personal Data against unauthorized disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
- i. Epinoyload’s related corporations and employees to provide content, Products and Services to you, address your questions and requests in relation to your customer accounts, transactions and billing arrangements with us as well as our Products and Services, to activate, deactivate, install, maintain and operate our systems and/or services;
- ii. Companies providing their services to Epinoyload;
- iii. Agents, contractors or third party service providers who provide operational services to Epinoyload, such as telecommunications, information technology, and payments.
- iv. Vendors or third party service providers in connection with marketing promotions and services offered by Epinoyload or its preferred partners;
- v. Other telecommunications, content or other service providers to facilitate their provision of content or services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers;
- vi. Any business partner, investor, assignee or transferee (actual or prospective) to facilitate business transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
- vii. External banks, epayment facilities and their respective service providers;
- viii. Our professional advisers such as auditors and lawyers;
- ix. Relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority;
- x. Epinoyload clients or partners, if your job application is in accordance with a staff augmentation or placement agreement with the partner; and
- xi. Any other party to whom you authorize us to disclose your Personal Data to.
Storage, Retention, and Disposal of your Personal Data
1. Epinoyload utilizes several different methods in the storage and retention of your Personal Data, including but not limited to cloud storage, physical and electronic files, etc. Epinoyload ensures that it shall always maintain the security of your Personal Data and will always act in accordance with this Agreement, as regards to the storage and disposal of these information.
2. Epinoyload shall retain Personal Data (including but not limited to those included in electronic documents) to the extent that the Company is required to by law, and only for as long as necessary for the fulfillment of the purpose(s) for which the Personal Data has been collected or processed.
3. Epinoyload undertakes to dispose of your Personal Data in a secure manner, in accordance with Data Privacy Laws, and will ensure that the disposal shall prevent further disclosure, sharing or processing to any other party.
The information is then sent back to the server each time the browser requests a page from the server. This enables a web server to identify and track web browsers.
There are two main kinds of cookies: session cookies and persistent cookies. Session cookies are deleted from your computer when you close your browser, whereas persistent cookies remain stored on your computer until deleted, or until they reach their expiry date.
Cookies on our website and mobile app
Epinoyload uses the following cookies on this website and on its mobile app, for the following purposes:
1. To help us remember and process the service you purchase
2. To help us understand your preferences based on previous or current activity, which enables us to provide you with improved services
3. To check for fraudulent actions.
Cookies are used by the following services:
Opt out, remove or modify your Personal Date
1. You can request to have your information removed by clicking on the Contact Us on this app or website. Please note that we may maintain information about an individual sales transaction in order to complete that transaction and for record keeping purposes. If you:
c. Would like to obtain access and make corrections to your Personal Data records; or
d. Would like to report any threatened or actual breach of your Personal Data, please contact Epinoyload as follows:
Telephone: +63 2 8 528 8700
2. Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer), you should contact that organization or individual to make such queries, complaints, access and correction requests to Epinoyload on your behalf.
3. You also have the right to file a complaint directly with the National Privacy Commission for any violation of your data privacy rights.
Management of Personal Data
1. Epinoyload maintains reasonable and appropriate organizational, physical, and technical measures in order to protect your Personal Data from accidental or unlawful destruction, alteration, disclosure, and other unlawful processing.
2. In accordance with the Data Privacy Act of 2012, a Data Protection Officer has been appointed to manage and protect your Personal Data. Breaches shall be reported with dispatch, and Epinoyload will endeavor to always ensure that its Privacy Management Programs are always monitored and updated to be at par with future developments.
3. In the event that Epinoyload verifies that there has been an actual data breach, or when there is reasonable belief by Epinoyload that a personal data breach requiring notification has occurred, it shall notify the National Privacy Commission and the affected data subjects of such data breach, in accordance with the Data Privacy Act of 2012 and other relevant Data Privacy Laws.
By using our website and our app, and by availing our products and services directly from Epinoyload or through our Business Partners, you confirm that:
- a. you are of legal age, and you have the capacity to legally bind yourself to the terms of this Policy;
- b. you fully understand all the terms and conditions stated in this Policy; and
- c. you consent to the processing of your Personal Data in accordance with the terms of this Policy.