Process Synergy Inc. (PROSYNC) ("PROSYNC", "We", “us” or “our”) respect your privacy and will keep secure and confidential all personal information and sensitive personal information (“Personal Data”) that you may provide and/or those that PROSYNC may collect from you.

This privacy statement (“Statement”) provides for the Personal Data we obtain, or which you may provide and the standards we observe in using, processing, keeping, securing and disclosing said Personal Data in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA).

Basis, Use, and Purpose for Processing of Personal Data

While your consent may be solicited to process your Personal Data, we may also process personal data without your consent, such as when processing is allowed under Section 12 or Section 13 of the DPA.

Your Personal Data is utilized for the purposes declared on each of the following:

For other Personal Data processing activities not mentioned above, We shall provide a separate privacy notice in an appropriate format to detail the purpose in which We process your personal data. In all instances, We assure you that processing your Personal Data will strictly follow the provisions of DPA, especially the general data privacy principles of Transparency, Legitimate Purpose, and Proportionality.

We may disclose and share your Personal Data, subject to compliance with applicable laws and regulations, on a need-to-know basis, and in all cases only for legitimate purposes, as follows:

• To our subsidiaries and affiliates;
• To contractors, service providers, and other third parties. We engage to support our business, and who are bound by contractual obligations to keep Personal Data confidential, and use it only for the purposes for which We disclose it to them;
• To government and law enforcement agencies and regulatory bodies;
• To comply with orders of courts, government agencies, regulatory bodies, stock exchanges and with other applicable laws and regulations;
• If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of PROSYNC our subsidiaries and affiliates, officers, employees, customers, or other third parties;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PROSYNC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by PROSYNC is among the assets transferred;
• To conduct investigations of breaches of PROSYNC’s internal policies, laws and regulations, enforce appropriate sanctions and pursue legal actions, if necessary.

Rights of a Data Subject

You are entitled to certain rights in relation to the Personal Data collected from you, including the right to access and correct your Personal Data being processed, object to the processing if based on consent or on legitimate interest, and to lodge a complaint before the National Privacy Commission in case of violation of your rights as data subject.

Risks Involved

Risk refers to the potential of an incident to result in harm or danger to a data subject or organization. Risks may lead to the unauthorized collection, use, disclosure, or access to personal data. It includes risks involving the confidentiality, integrity, and availability of personal data or the risk that processing will violate the general data privacy principles and the rights of data subjects.

PROSYNC ensures that adequate physical, technical, and organizational security measures are in place to protect Personal Data’s confidentiality, integrity, and availability. However, this does not guarantee absolute protection against certain risks involving the processing of personal data, such as when systems are exposed to targeted cyberattacks, malware, ransomware, and computer viruses or when manual records are accessed without authority.

However, adequate policies are in place to ensure appropriate security incident management in line with existing NPC policies, circulars, and other issuances.

Security of your Personal Data and the Collected Data

We have implemented technical, organizational, and physical measures designed to protect the confidentiality, integrity, and availability of your Personal Data and secure such data from destruction, unauthorized access, alteration, disclosure, fraudulent misuse and/or any other unlawful processing, as well as other natural and human dangers.

Contact Information

Should you have any questions and/or concerns regarding this Statement, PROSYNC’s use of your Personal Data, your rights in relation thereto under the Data Privacy Act of 2012, please do not hesitate to contact the PROSYNC’s Data Protection Officer at the following:

• Email: prosyncdpo@prosync.sanmiguel.com.ph
• Phone: (+632) 8632-2105
• Address: 2F San Miguel Properties Centre, #7 St. Francis St., Mandaluyong City

Changes in this Privacy Statement

We may update this Statement from time to time to reflect change(s) in the law and/or our internal standards. When We do so, We will notify you by posting the updated Statement on this Website for your information and reference. Prior versions of the Statement shall be retained by PROSYNC and shall be provided to data subjects upon request. The provisions of this Statement – 3rd version, are effective this 1st day of March 2024, until revoked or amended by PROSYNC.

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