Privacy Policy

INTRODUCTION

This Privacy Policy outlines how Greenfield Development Corporation and its subsidiaries, Greenfield Infrastructure Resources Management, Inc., Greenfield Marketers One, and Leopard Connectivity Business Solutions, collectively known as “Greenfield”, process (collects, uses, shares, and keeps) and protect your personal data as we, Greenfield, respect your right to privacy and recognize the need for appropriate measures to manage and protect your personal data from the risks of theft, disruption, and unauthorized access. This provides the steps that you can take should you wish to exercise your rights as a data subject in adherence with the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), other issuances of National Privacy Commission and other relevant laws of the Philippines.

Type of personal data collected

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”.

The data we collect depends on the context of your interactions with us. We collect information to provide you with details and information regarding our products, services, and promotions. We process information also to respond to your enquiries or perform necessary actions in accordance with our obligations or agreement. The common type of data collected by Greenfield from you, generally includes the following:

• 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.

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

Manner of collection of personal data

We collect data when you:

• Identify all methods of collections. Examples are as follows:
• Fill out our application forms and submit necessary documents;
• Encode your data in our websites and social media pages;
• Disclose your personal information through phone calls, emails, SMSs or verbal communication with our authorized third-party representatives;
• Provide personal information in relation to inquiries, requests, and complaints; and,
• When entering our building and property premises, we collect footages and images through our surveillance cameras.

Purpose of processing of personal data

To enable us to perform process related to our operations and to comply with our corporate policies in relation to data subjects 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, we are using your data for any of the following purposes:

• To perform functions necessary to deliver our products and services;
• To maintain quality service, monitor the security and provide support services timely and efficiently;
• To respond to specific complaints, enquiries, requests or manage future interactive user function it may be necessary to ask for personal information;
• To notify and update you (through call, text or email) about our complimentary, commercial and promotional advertisements, exclusive invites, discounts, surveys, and other direct marketing that we deemed relevant and beneficial to you based on your preference and interest initially provided to us or made aware of, with which you can opt-out anytime should you prefer not to receive these notifications;
• During events we may obtain your personal information or take a picture of attendees which may be used for documentation and reporting for internal purposes. Also, we may use these pictures for our promotional activities and advertisements in social media pages and websites. We assure you that we treat all of our customers’ information confidential and we will prevent any unauthorized disclosure of it by our employees or any third party;
• To serve as a historical or statistical basis when conducting research and analysis in order to improve customer experience or satisfaction;
• To comply with legal and regulatory requirements or obligations; and
• To perform such other processing or disclosure that may be required under law or regulations

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:

1. When you want to become a part of our team [for employment]:
• Evaluate your suitability for the position you are applying for and communicate with you the progress of your employment application
• Maintain a record of your profile to monitor the status of your employment;
• Process your data necessary for your employment such as, but not limited to, payroll, allowances and refunds processing, tax processing, medical examination, processing of legal cases and other purposes that may demand processing of your personal data;
• Conduct performance evaluation and career development programs;
• Facilitate interview and assessment on your separation from the company;
• Process your clearances and final pay;
• Serve as a basis in improving human resource management of the company; and
• Perform any other action as deemed to be necessary to implement the terms and conditions of our employment agreement
2. When you inquire or acquire a property [for purchase of property]:
• Administer the acquisition of units or property and prepare all necessary documentation as a result of our transaction;
• Facilitate pre-qualification assessment, registration, billing, endorsement to financing and other activities relevant for the acquisition of unit or property;
• Update our records and keep your contact details for the facilitation of your unit reservation, viewing, and other queries;
• Serve as a basis for profiling prospective buyers’ preferences and demographic information for marketing purposes;
• Communicate all advisories and changes in relation to unit reservation, viewing and other transactions; and
• Perform other processes related to or in connection with our business, including those processing or disclosure that may be required under law or regulations
3. When you apply to become a tenant or merchant in any of our properties for lease [for lease/tenant]:
• Administer the lease of units or property and prepare all necessary documentation as a result of our transaction;
• Facilitate registration, billing, endorsement to financing and other activities relevant for the lease of unit or property;
• Manage your account, provide customer care activities, monitor our quality and security, and provide services timely and efficiently;
• Inform you about our exclusive offers, discount, promotional projects and other direct marketing that we deemed relevant and beneficial to you based on your preference and interest initially provided to us or made aware of; and
• Perform other processes related to or in connection with our business, including those processing or disclosure that may be required under law or regulations
4. When you are a vendor, a potential vendor, or a contractor [for vendors]:
• Register you as an accredited supplier of the Company’s products or services;
• Validate and identify your identity;
• Conduct due diligence and assessment;
• Ensure legitimacy of your business operation;
• Perform any other action as may be necessary to implement the terms and conditions of our contract; and
• Perform other processes related to or in connection with our business, including those processing or disclosure that may be required under law or regulations
5. When you are an agent, a broker or a network partner [for sales agents, brokers and network partner]:
• Consider and evaluate your suitability for the position you are applying for;
• Communicate with you the result of your application as sales agent;
• Register you in our system for the purpose of tracking your application status; and
• Perform any other action as deemed to be necessary to implement the terms and conditions of our contract agreement
• Facilitate the accreditation process for licensed broker and endorsement as a network partner;
• Evaluate and validate your identity by conducting due diligence and assessment to ensure the legitimacy;
• Register you as our accredited licensed broker of the Company’s products or services;
• Monitor your activities and performances whether it is consistent with the agreed terms;
• Serve as a reference for creating vendor code registered in our software application system;
• Perform any other action as deemed necessary to implement the terms and conditions of our agreement; and
• Perform other processes related to or in connection with our business, including those processing or disclosure that may be required under law or regulations
6. When you are part of our manpower service providers [for contractual]:
• Assess your suitability for the job you are applying for;
• Conduct screening on your background, capacity and availability as a contractual or on-call personnel; and
• Perform any other action as deemed to be necessary to implement the terms and conditions of our contract agreement
7. When you avail our Information and Communications Technology (ICT) services [for Leopard customers]:
• Keep your information and contact details for the facilitation of internet connection;
• Know what type of broadband package you want to avail;
• Inform you of any service or promo package we are offering;
• Perform any other action as deemed to be necessary to implement the terms and conditions of our agreement.

Use of 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. To find out more about cookies please visit www.allaboutcookies.org.

Third Party Links

This Site contains links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other Sites which you choose to access from this Site. We encourage you to review the privacy policies of those other Sites, so you can understand how they collect, use and share your personal information.

Transfer of personal data

Generally, we are not allowed to share your data to third party except in limited circumstances as listed below.

By giving your consent, you authorize Greenfield 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, as noted in the table at the end of this notice, 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.

Protection of 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 Greenfield 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 keep and protect your personal data using a secured server behind a firewall, deploying encryption on computing devices and physical security controls.
• We restrict access to your personal data only to qualified and authorized personnel who hold your personal data with strict confidentiality.
• Any personal data that you provide on our website is initially processed and stored by Greenfield. Using a secured connection, only authorized Greenfield personnel can then access and download your personal data from the system.
• We have contracted a 3rd party payment services provider to process all related online payments. As such, we do not store your credit card information. Please refer to Pesopay Privacy Policy at http://www.pesopay.com/privacy-policy.html.
• 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.

Retention of personal data

The personal data are stored in our facilities located in the Philippines and are retained in accordance with our retention schedule 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.

Changes in Privacy Policy

Greenfield 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.

Exercising rights as a data subject

To exercise your rights which include 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 Greenfield, you may reach us through our “Contact Us” menu in this website: www.greenfield.com.ph, through a written letter or through an email to our Data Protection Officer (DPO).

Our contact details are as follows:
GDC Data Protection Officer
#88 United St. GDC Corp. Center Greenfield District, Mandaluyong City 1550
dpo@greenfield.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.

Additional Clause for General Data Protection Regulation (GDPR) and Cross Border Data Protection Laws

We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this notice sets out the lawful basis we rely on for each type of data we process.

We will choose one of the lawful bases in the GDPR to justify how we use your personal data. These are:

• Consent: You have given consent to the processing of your personal data for one or more specific purposes.
• Contract: The processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.
• Legal obligation: We need to process your personal data to comply with a legal obligation.
• Vital interests: The processing is necessary to protect the vital interests of you or another person.
• Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.
• Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

 

Table: List of third-party/-ies to which we share your personal data