HAVAS MEDIA ORTEGA, INC. PRIVACY POLICY

Havas Media Ortega, Inc. (“Havas Ortega”, “We”, “Us”, “Our”) is committed to recognizing and protecting your data privacy rights as a Filipino citizen in accordance with the Philippine Data Protection Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations.

In this Privacy Policy, you will understand how we collect and use your Personal Data when you use our services, including when you interact with our website. This Privacy Policy may also serve as your guide in exercising your rights under the Philippine Data Protection Act of 2012. All personnel of Havas Ortega, regardless of type of employment or contractual arrangement, are required to comply with the contents of this Privacy Policy.

This Privacy Policy was last reviewed and updated on 22nd June 2023.

Definitions

• Data Privacy Act or DPA refers to the Republic Act 10173, the Data Privacy Act of 2012 and its Implementing Rules and Regulations.
• Data Subject refers to an individual whose Personal Information, Sensitive Personal Information, or Privileged Information is processed
• Company refers to Havas Media Ortega, Inc.
• Personal Information, Personal Data refers to any information, whether recorded in a material form or not, from which 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 or indirectly identify an individual
• Processing refers to any operation or set of operations performed upon Personal Data including, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure, or destruction of Personal Data. Processing may be performed through automated means, or manual processing, if the Personal Data are contained or are intended to be contained in a filing system.
• Privileged Information refers to any and all forms of Personal Information, which, under the Rules of Court and other pertinent laws constitute privileged communication.
• Security Incident is an event or occurrence that affects or tends to affect data protection, or may compromise the availability, integrity, or confidentiality of Personal Data. It includes incidents that would result to a Personal Data breach, if not for safeguards that have been put in place.
• Sensitive Personal Information, Sensitive Personal Data refers to Personal Information
  • About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical, or political affiliations;
  • About an individual’s health, education, genetic or sexual life, or to any proceeding for any offense committed or alleged to have been committed by such individual, the disposal of such proceedings, or the sentence of any court in such proceedings;
  • Issued by government agencies peculiar to an individual which includes , but is not limited to, social security/SSS numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and
  • Specially established by an executive order or an act of Congress to be kept classified.

What Personal Data We Collect from You

At Havas Ortega, we may collect the following Personal Data from you when you –

• Sign up for Havas Ortega’s email newsletters
• Work with Havas Ortega on specific marketing and advertising projects
• Use our website
• Take part in marketing research and surveys
• Join our on-ground and/or online events
• Apply for a position within our Company, whether as a permanent or part-time employee, contractor, or intern
• Become our vendor/partner, supplier, employee, or contractor

Depending on the nature of our relationship with you, here are some of the data that we may be collecting from you

• Complete Name
• Email address
• Mobile phone number and/or other contact numbers
• Employment and educational background and history
• Tax Identification Number, Social Security Number, VAT Registration Number
• Physical address/snail mail address

The specific data that we will be requesting from you will be dependent on the nature of the relationship or relationships that you have with Havas Ortega. We aim to collect only the minimum amount of data from you for us to fulfill our roles and responsibilities to you, depending on our relationship with you. When we collect these data from you, we will also let you know the purpose for which we will use the data that we have collected from you whilst ensuring that your Personal Data will be processed in accordance with the Data Protection Act/DPA.

Automatically Collected Personal Data

When you visit our website, certain information is automatically collected by cookies, web beacons, and similar technologies. This may include your IP address, browser type, device information, operating system, and usage data. No personally identifiable information is collected whilst browsing our website. This information is collected to enhance your experience on our website, measure the effectiveness of our website through services such as Google Analytics, and thereby improve our services and our content to serve you better.

You can withhold or opt out of the automatic collection of your data on our website by clicking on the appropriate button on one of our prompts upon landing on our website.

We Do Not Sell Your Data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

Data Security and Retention

We implement reasonable security measures to protect your Personal Data from unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

We will retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and/or as outlined in our relationship with you (e.g., as an employee, as an applicant, as a vendor, as a client), unless a longer retention period is required or permitted by law.

Your Rights

1. The Right to be Informed. You have the right to be informed whether your Personal Data shall be, are being, and/or have been processed. We will notify and furnish you at the time of collection of your Personal Data or within a reasonable amount of time after collection of your Personal Data the purpose of our processing, as well as its scope and methods.
2. The Right to Object. You have the right to object to the processing of your Personal Data, including processing for direct marketing, automated processing, or profiling. You also have the right to withhold or withdraw consent for the processing of your Personal Data. Once you withhold or withdraw your consent of your Personal Data, we will no longer process your Personal Data and will delete it from our databases and systems accordingly.
3. The Right to Access. You have the right to reasonable access to your Personal Data that we may have processed. You also have the right to reasonable access to the method through which we acquired your Personal Data and how we process your Personal Data. You also have the right to contact our Data Protection Officer at dpo.philippines@havasmediaortega.com for more clarity on your Personal Data and the processing of which.
4. The Right to Rectification. You have the right to dispute the inaccuracy of your Personal Data and/or to rectify any errors or omissions on your Personal Data. Upon receipt of your notice of rectification, the Company shall endeavor to correct it immediately and accordingly, unless the request is unreasonable.
5. The Right to Erasure or Blocking. You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your Personal Data from the Company’s filing system. This right may be exercised upon discovery and substantial proof of any of the following:
   1. The Personal Data is incomplete, outdated, false, or unlawfully obtained;
   2. The Personal Data is being used for purposes not authorized by you;
   3. The Personal Data is no longer necessary for the purposes for which they were collected;
   4. You withdraw consent and/or object to Processing, and there is no legal ground or overriding legitimate interest for the Processing by the Company;
   5. The Personal Data concerns private information that is prejudicial to you, unless justified by freedom of speech, of expression, or of the press or otherwise authorized;
   6. The Processing is unlawful; and/or
   7. Your Rights have been violated.
6. Transmissibility of Your Rights. Your lawful heirs and assigns may invoke your rights at any time after your death or incapacitation or incapacity to exercise your Rights.
7. The Right to Data Portability. You have the Right to obtain a copy of your Personal Data in digital, electronic, structured form that is commonly used for your further use.
8. The Right to Damages. You have the right to be indemnified for damages sustained, if any, due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your Personal Data.

Security and Subcontracting

Havas Ortega places particular importance on the security of your Personal Data.

Therefore, Havas Ortega has implemented technical and organizational measures tailored to the nature of the Personal Data, in order to ensure the integrity and confidentiality of such Personal Data and to protect them against malicious intrusion, loss, alteration, or disclosure to unauthorized third parties.

Nevertheless, the security and confidentiality of Personal Data depend on everyone’s best practices and you are encouraged to remain vigilant regarding this issue.

When Havas Ortega uses a processor, we only disclose Personal Data to it after having obtained a commitment and guarantees from said processor regarding its ability to meet the security and confidentiality requirements and entered into a written contractual commitment with it.

Third-Party Websites and Social Networks

Havas Ortega’s websites or services may provide links to third-party applications, products, services or websites to facilitate your browsing and for your information. If you access these links, you will leave the Website. Havas Ortega does not control these third-party websites or their privacy and data protection practices, which may differ from ours. We do not finance or represent any of these third-party websites and accept no responsibility for their content or their practice in terms of Personal Data protection. Personal Data you choose to provide via such websites or which are collected by such third parties are not covered by the Havas Ortega Privacy Policy. We encourage you to review the privacy policy of any website with which you interact before allowing your Personal Data to be collected and used.

We also provide links to social networks that allow you to share information with your own social networks and interact. When you use these links, information about you may be collected or shared. We encourage you to review the privacy policies of the social networks with which you interact, to find out the information that may be collected, used, or shared by these websites. If you post, comment, indicate interests, or share Personal Data in any public forum, social network, blog or any similar forum, please note that any Personal Information you post may be collected or used by other users of these forums and networks. In any event, Havas Ortega may not be held liable for such third-party uses which are not its responsibility.

Changes to the Privacy Policy

Havas Ortega reserves the right to amend this policy, for example, to comply with changes in the law and regulations, Havas Ortega and Havas global practices and procedures, or requirements imposed by the National Privacy Commission. Should there be amendments to the policy, they will be immediately published on the Havas Ortega website. Please check it regularly.
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If you have any questions or comments about this policy, please contact our Havas Ortega Data Protection Officer at dpo.philippines@havasmediaortega.com