I. PRIVATE POLICY
HEALTH CODE INTERNATIONAL CORPORATION (HCIC) (hereinafter
referred to as “the Company”) values and respects your right to privacy. We are
committed to protect the privacy of our website visitors. We will only collect,
record, store, process, and use your personal information in accordance with the
Data Privacy Act of 2012, its Implementing Rules and Regulations, the issuances
by the National Privacy Commission, and other pertinent laws.
This Privacy Policy informs you of updates in our corporate policies
regarding the collection, use, storage, disclosure, and disposal of personal
information we receive and collect from our customers, and any individual who
communicates, raises inquiries and concerns, as well as transacts with us
through our authorized representatives.
We will only use your data based on the limitations set by this policy. The
outline below provides the manner by which we manage the personal information
that we will obtain from you if you visit our website.
II. PERSONAL INFORMATION
Personal Information refers to any information, whether recorded in a
material form or not, from which the identity of an individual is apparent or can
be reasonably and directly ascertained by the entity holding the information, or
when put together with other information would directly and certainly identify
an individual. Sensitive Personal Information is any attribute of your personal
information that can discriminate, qualify, or classify you such as your age, date
of birth, marital status, government-issued identification numbers, account
numbers, and financial information. Privileged Information is any and all
forms of information which, under the Rules of Court and other pertinent laws,
constitute privileged communication.
Under the Data Privacy Act of 2012, you have the following rights:
a. Right to be informed – you may request the details as to how your
personal information is being processed or have been processed by the Company,
including the existence of automated decision-making and profiling systems;
b. Right to access – upon written request, you may demand reasonable
access to your personal information, which may include the contents of your
processed personal information, the manner of processing, sources where they
were obtained, recipients and reason of disclosure;
c. Right to dispute – you may dispute inaccuracy or error in your personal
information in the Company systems through our representatives;
d. Right to object – you may suspend, withdraw, and remove your personal
information in certain further processing, upon demand, which include your
right to opt-out to any commercial communication or advertising purposes from
the Company;
e. Right to data erasure – based on reasonable grounds, you have the right
to suspend, withdraw or order the blocking, removal or destruction of your
personal data from the Company’s filing system;
f. Right to secure data portability – you have the right to obtain from the
Company your personal information in an electronic or structured format that
is commonly used and allows for further use;
g. Right to be indemnified for damages – as data subject, you have every
right to be indemnified for any damages sustained due to such violation of your
right to privacy through inaccurate, false, unlawfully obtained or unauthorized
use of your information; and
h. Right to file a complaint – you may file your complaint or any concerns
with our office.
III. COLLECTION OF PERSONAL INFORMATION
We collect any of the following categories of Personal Data about Site
visitors, clients, prospective clients, and other third parties:
a. Device data: Computer Internet Protocol (IP) address, unique device
identifier (UDID), cookies and other data linked to a device, and data about usage
of our website (Usage Data)
b. Basic and Client Service data: Name, gender, title, organization, job
responsibilities, customers, phone number, mailing address, email address and
contact details;
c. Social Media data: Pictures, gender, date of birth, relationship status,
interests and hobbies, educational background, and employment details, or any
other matters which are readily accessible if you link your account with our
website;
d. Registration and Marketing data: Newsletter requests, event/seminar
registrations, subscriptions, data about participation in conferences, seminars,
credentials, associations, product interests and preferences;
e. Transaction data: Personal data contained in documents,
correspondence or other material provided by or relating to transactions
conducted with or by our clients/prospective clients.
f. Compliance data: Government identifiers, passports or other
identification documents, dates of birth, beneficial ownership data, and due
diligence data;
g. Job applicant data: Data provided by job applicants or others on our
website or offline means in connection with employment opportunities, which
also may be subject to an additional relevant local recruitment privacy policy.
We will only collect your personal information if you voluntarily submit the
information to us. If you choose not to submit your personal information to us
or subsequently withdraw your consent to our use of your personal information,
we may not be able to adequately respond to your inquiries or avail of our
services.
When we receive data from our clients about employees, customers or other
individuals, the client is responsible for ensuring that any such data is
transferred to us in compliance with applicable data protection laws.
IV. USE OF PERSONAL DATA
The purposes for which we use Personal Data are as follows:
a. To provide consultation advice and respond to inquiries. For this, we use
basic and client service data, transaction, and device data.
b. To manage our business operations, the website, and our client
relationships. For this, we use basic and client service data, registration data,
and marketing data.
c. To make our Site intuitive and easy to use. For this, we use device data. It
is necessary for our legitimate interests to monitor how our Site is used to help
us improve the layout and information available on our website and provide a
better service to our website users.
d. To protect the security and effective functioning of our website and
information technology systems. For this, we use basic and client service data,
registration data, transaction data, and device data. It is necessary for our
legitimate interests to monitor how our website is used to detect and prevent
fraud, other crimes and the misuse of our website. This helps us to ensure that
you can safely use our website.
e. To provide relevant marketing, such as providing you with information
about events or services that may be of interest to you including services,
updates, client conferences or networking events, and groups of specific interest.
For this, we use registration and marketing data, basic and client service data,
as well as device data. It is necessary for our legitimate interests to process this
information in order to provide you with tailored and relevant marketing, updates
and invitations.
f. To address compliance and legal obligations, such as complying with the
Company’s reporting obligations, checking the identity of new clients and to
prevent money laundering and/or fraud. For this, we use compliance data, basic
and client service data, registration data, transaction data, and device data.
g. To consider individuals for employment and contractor opportunities and
manage on-boarding procedures. For this, we use job applicant data and
compliance data. The processing is necessary for purposes of recruitment and
on-boarding and for complying with legal obligations to which we are subject,
and which may be subject to a relevant local recruitment privacy policy.
If you submit personal information for publication on our website, we will
publish and otherwise use that information in accordance with the permission
given to us.
Your privacy settings can be used to limit the publication of your
information on our website and can be adjusted using privacy controls on the
website.
We will not, without your express consent, supply your personal
information to any third party for the purpose of their or any other third party’s
direct marketing.
V. SHARING OF PERSONAL DATA
We may share Personal Data with the following categories and recipients:
a. Affiliates and Service Providers: If requested and/or approved by the
client or prospective client, we will share personal data with our trusted affiliate
companies and service providers in order to provide you with adequate services
in relation to our business and those of our affiliates and service providers.
b. Financial institutions: We may share Personal Data with financial
institutions in connection with invoicing and payments.
c. Mandatory disclosures and Legal Claims: We share Personal Data in
order to comply with the Company’s tax reporting obligations, comply with any
subpoena, court order or other legal process, to comply with a request from
regulators, governmental request or any other legally enforceable demand. We
also share Personal Data to establish or protect our legal rights, property, or
safety, or the rights, property, or safety of others, or to defend against legal
claims.
VI. DATA RETENTION AND DISPOSAL
We typically retain Personal Data related to marketing activities for as long
as you accept marketing communications from us, and we will securely delete
such data in accordance with applicable laws upon request. For Personal Data
that we collect and process for other purposes, we will typically retain such
Personal Data for as long as it is necessary to fulfill the purposes outlined in the
Privacy Policy, Cookies Policy, as well as the Terms of Use. Deletion of such data
may be done at any time upon your request.
VII. COOKIES POLICY
Our website uses cookies to optimize user experience.
What are cookies?
Cookies are small amounts of data that are stored on your browser, device, or
the page you are viewing. Some cookies are deleted once you close your browser,
while other cookies are retained even after you close your browser so that you
can be recognized when you return to a website.
How do we use cookies?
We use cookies in order to gather information about your usage patterns when
you navigate the Site in order to enhance your personalized experience, and to
understand usage patterns to improve our Site’s services.
Categories of cookies on our Site:
a. Analytical/Performance Cookies: These allow us to recognize and
count the number of users of our Site and understand how such users navigate
through our Site. This helps to improve how our Site works, for example, by
ensuring that users can find what they are looking for easily. These cookies are
session cookies which are erased when you close your browser.
b. Functional Cookies: These improve the functional performance of
our website and make it easier for you to use. For example, cookies are used to
remember that you have previously visited the website and asked to remain
logged into it. These cookies qualify as persistent cookies, because they remain
on your device for us to use during a next visit to our website. You can delete
these cookies via your browser settings.
c. Cookie Pop Up – We use a cookie to determine if you have read our
cookies consent pop up and to ensure we do not show it to you again when you
dismiss it.
What are your options if you do not want cookies on your computer?
You can review your Internet browser settings, typically under the sections
“Help” or “Internet Options,” to exercise choices you have for certain Cookies. If
you disable or delete certain Cookies in your Internet browser settings, you might
not be able to access or use important functions or features of this Site.