PRIVACY POLICY

COMPLIANT BUSINESS PROCESSING PHILIPPINES INC. (CBPPI) is a 100% Australian-owned Business Process Outsourcing (BPO) organization situated in the Philippines that specializes in supporting the international and multi-modal freight and logistics industry. Its Manila office is located at KMC Mag Solutions, Inc., 10th Floor, South Tower, Rockwell Business Center, Sheridan, Mandaluyong City, Philippines.

Please carefully read this Privacy Notice ("Notice") to understand our practices regarding processing your Personal Information. This notice shall serve to inform you of how we collect, process, retain, disclose, and dispose of your Personal Information and how you can avail of your rights as a Data Subject under Republic Act 10173 also known as "The Data Privacy Act of 2012".

The following provides an overview of how your privacy is protected on this website:

1. HOW WE COLLECT YOUR PERSONAL DATA?

CBPPI collects personal data through the following:

• Visiting or connecting with us through our websites (e.g cookies, Contact Us forms) and through our official social media platforms (e.g Facebook, Youtube).
• Inquiring about any of the services that we offer
• Responding to our direct electronic mail (e-mail) messages sent by us as part of our client services, sales and marketing campaigns
• When you referred to us by one of our clients and/or business partners
• When you enter into an agreement or contract with us to provide you with our services
• When you submit your CV and job application form (via email, referral from our employees and via a job portal)
• When you sign a contract to join our company as employees
• When you submit your information through us to liaise with relevant government agencies on your behalf.

2. WHAT ARE THE TYPES OF PERSONAL DATA THAT WE COLLECT?

CBPPI collects the types of personal data including, but not limited to, the following:

• Contact Information (Name, Address, Phone number, Email address)
• Identification (Social security number, Driver's license, Passport number)
• Biometrics (Facial recognition, fingerprints)
• Financial Information (Bank account, credit card data, e-bank account)
• Health Information (Medical history, health condition, prescription information)
• Education (School records, degree, certification, training, academic performance)
• Employment (job history, professional qualifications, salary details, performance evaluation)
• Online Identifiers (IP Address, cookie data, usernames, social media profiles)
• Location (GPS coordinates, Geolocation)

3. HOW DO WE USE THIS INFORMATION?

CBPPI uses the personal data you provide us for one or more of the following purposes:

• Communicate with customers, members and website visitors (including when you leave a comment on our websites)
• Comply with or fulfill legal obligations and regulatory requirements
• Analyze your visits to our website and social media platforms, and respond to your inquiries and feedback to improve our quality of service
• Analyze the use of our services or websites
• Process job applications, recruitment and selection
• Process account payables/receivables
• Process billing, payment and other credit-related activities
• Process employment requirements of our employees with the relevant government agencies
• Process visa applications of our employees with the relevant government agencies
• Carry out our obligations arising from any contracts entered between us and our clients

4. DO WE SHARE YOUR INFORMATION WITH OUTSIDE PARTIES?

CBPPI discloses some of the personal data you provide us with the following entities or organization outside CBPPI to fulfill our services and obligations to the following stakeholders:

• Local and international clients
• External service providers
• Cloud Service Providers
• Applicable Local Government Agencies
• Applicable Australian Government Agencies

Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.

5. HOW WE MANAGE THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA

A. CONSENT

Before we collect, use or disclose your personal data, we will notify you of the reason why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose.

We will seek new consent from you if the original purpose for the collection, use or disclosure of your personal data has changed.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, (e.g. when you apply for a job with us using our job application forms.)

We may rely on exceptions to the need for consent under the DPA for the collection, use or disclosure of your personal data under the following circumstances (only those relevant to CBPPI are included):

• The personal data is publicly available, disclosed by a public agency or disclosed to a public agency
• The personal data is necessary for any investigation or proceedings
• The personal data is necessary for evaluative purposes (e.g. determining the suitability of a job applicant for the job applied for)
• The personal data is necessary for the fulfillment of obligations under contractual agreements
• Personal data is necessary for compliance with legal obligations
• Personal data is necessary to protect vitally important interests of the data subject, including his or her life and health.
• Personal data is necessary to pursue the legitimate interest of the organization and/or the third party or parties to whom the data is disclosed.

B. WITHDRAWAL OF CONSENT

You have choices regarding our collection, use or disclosure of your personal data. If you choose not to provide us with the personal data described in this Notice, we may not be able to process your required services. You have the right to object to the processing of your personal data and withdraw your consent in the manner described in this section.

If you wish to withdraw consent, you may inform us via the contact information provided in Section 12 of this Notice. Allow us to process your concern and respond to you within the most reasonable time so we can advise you of the likely consequences of your withdrawal of consent (e.g. not able to proceed with recruitment and/or process other needed requirements).

C. COOKIE POLICY

We use cookies to collect information about your online activity on our website. Cookies are small files that save and retrieve information about your visit to the CBPPI website such as how you entered and navigated through our site. The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or fill in electronic forms.

The cookies we use identify you by number, not by name. Most cookies we use are session cookies, which will be deleted automatically from the hard disk of your computer at the end of the session.

If you are uncomfortable with the use of cookies, you can disable cookies on your computer by changing the settings in the preferences or options menu of your browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.

D. THIRD-PARTY CONSENT

We do not get consent on behalf of another individual or party. We only get consent from the individual who will be dealing directly with us.

6. HOW WE ENSURE THE ACCURACY OF YOUR PERSONAL DATA

We take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and always up to date.

For our internal and external stakeholders, we may send an email or message verifying if the data provided to us is still updated and may request or inform us on any changes to the personal data we are currently maintaining.

7. WHAT ABOUT DATA SECURITY?

We have implemented appropriate physical and technical measures to protect the personal data we hold about you against loss, misuse, destruction, unauthorized alteration/modification, access, disclosure and other similar risks. These are governed by our internal data protection and information security policy.

We have also put in place reasonable and appropriate organizational measures to maintain the confidentiality and integrity of your personal data and will share your data with authorized people if and only it is deemed necessary.

We ensure that we only engage with third-party data processors who shared the same mission with us in terms of safeguarding and taking care of your personal data. We will ensure that they provide sufficient measures to have implemented the necessary organizational and technical security measures and have taken reasonable steps to comply with these measures.

8. HOW WE RETAIN YOUR PERSONAL DATA?

CBPPI follows its internal document retention policy in keeping track of the retention schedules of the personal data you provide us with, both in physical and digital forms. CBPPI will not retain any personal data when it is no longer needed for any business or legal purposes.

We will dispose of or destroy such documents containing your personal data in a proper and secure manner once the retention limit is reached.

9. WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?

As a data subject, you have specific rights regarding your personal data, which we are committed to upholding. These rights include:

1. Right to be Informed: You have the right to be informed about the collection and use of your personal data.
2. Right to Access: You have the right to access your personal data and obtain a copy of the data we hold about you.
3. Right to Rectification: You have the right to request the correction of any inaccuracies or errors in your personal data.
4. Right to Erasure: You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected.
5. Right to Restrict Processing: You have the right to request the restriction of processing of your personal data in certain circumstances.
6. Right to Object: You have the right to object to the processing of your personal data for certain purposes, such as direct marketing.
7. Right to Data Portability: You have the right to request the transfer of your personal data to another organization or to yourself in a structured, commonly used, and machine-readable format.
8. Right to Withdraw Consent: Where you have provided consent for the processing of your personal data, you have the right to withdraw your consent at any time.
9. Right to Lodge a Complaint: You have the right to lodge a complaint with the appropriate data protection authority if you believe that your rights have been violated.

If you have concern, you can reach us by sending an e-mail at sales@compliantbusinessprocessing.com.

10. HOW OFTEN DO YOU UPDATE YOUR PRIVACY NOTICE?

We may update our Data Protection Policy from time to time. We will notify you of any changes by posting the latest notice on our website. Please visit our page periodically to note any changes. Changes to this notice are effective once they are posted.

11. CONTACTING US

If you have questions or feedback regarding this Privacy Notice, or if you have any complaint relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at dpo@compliantbusinessprocessing.com.