Privacy Notice (Philippines)

Updated: 07 August 2024

  1. INTRODUCTION

    Involve Asia (“Involve Asia”, or “IA”, or "we" or "us" or “our”) are committed to protect and respect your rights to your personal data. In compliance with the Republic Act No. 10173 or “the Data Privacy Act of 2012”; related rules, regulations, and issuances of the National Privacy Commission (“NPC”); and with the adoption of constantly changing commercially acceptable standards for data protection (collectively, the “Data Privacy Laws”). This notice (“Privacy Notice” or “Notice”) is issued to all our clients, customers, and users, both current and prospective, and any other person who accesses or uses our Website (defined below), downloads or uses our Applications, or avails of our Services, interact with us, or enter(s) into any engagement with us (“you”, “your”, “user”, “users” or “data subject”). This Notice will inform you of your rights with regard to your Personal Data that has been and/or will be, collected, used, processed, and disclosed by us.

    Please read our Privacy Notice to know the “whys”, “whats”, “whens”, “hows”, and “who's/'re”, among others, of our Notice for our community's data protection.

  2. GENERAL
    1. Involve Asia shall include:
      1. INVOLVE ASIA TECHNOLOGIES SDN BHD, bearing Company Registration Number 201201032669 (1017157-V) and having its principal place of business at 18-01 & 18-03, Level 18 Menara MBMR, Jalan Syed Putra, 58000 Kuala Lumpur, Malaysia;
      2. VAL MEDIA SDN BHD bearing Company Registration Number 201801039139 (1301170-H) and having its principal place of business at 18-02, Level 18 Menara MBMR, Jalan Syed Putra, 58000 Kuala Lumpur, Malaysia;
      3. INVOLVE ASIA (THAILAND) CO., LTD. bearing Company Registration Number Registration No. 0105561090991 and having its principal place of business at 111 True Digital Park West, Unicorn Building, 9th Floor, Unit 915, Sukhumvit Road, Bangchak, Phra Khanong, Bangkok - 10260, Thailand;
      4. INVOLVE ASIA PTE. LTD bearing Company Registration Number 201603369M and having its principal place of business at 150, Orchard Road #08-01, Orchard Plaza - 238841, Singapore; and
      5. PT INVOLVE ASIA INDONESIA bearing Company Registration Number 9120301431269 and having its principal place of business at Gedung Noble House, Lantai 29, Nomor Unit 133, Jalan Dr. Ide Anak Agung Gde Agung Kavling E4.2 Nomor 02, Rukun Tetangga 005, Rukun Warga 003, Kelurahan Kuningan Timur, Kecamatan Setiabudi, Kota Jakarta Selatan, Propinsi Daerah Khusus Ibukota Jakarta - , Indonesia.
    2. By expressly providing your consent to our Privacy Notice, and by accessing, benefitting from, or using, our varied platforms, whether in print or via our online software systems, directly or indirectly, such as the latest official build of our Website, Applications [https://app.involve.asia/advertiser] and Services for users in Philippines where we collect certain personal information (“Personal Data”), you hereby acknowledge that you have read, understood, and agree to the terms of our Privacy Notice, Cookie Policy, and any other documents that are referred in this Privacy Notice. You agree to have your data collected, corrected, transferred, stored, retrieved, used, retained, shared, deconstructed, and/or destroyed in the manner disclosed in this Privacy Notice. This Privacy Notice applies to all people and entities accessing our Platforms.
    3. This Privacy Notice explains our Notice regarding the collection, use, retention, disclosure, and transfer of your information by Involve Asia. Please read this Privacy Notice carefully as it contains important information to help you understand our practices regarding any personal information that you provide to us or that we collect otherwise in the context of our Website, Applications, and Services and the ways in which you can protect your privacy.
    4. We respect the privacy of the users of the Applications and are committed to reasonably protecting it in all respects. The information about the User as collected by us are: (a) information supplied by Users; and (b) information automatically tracked while using a mobile device having Involve Asia Services enabled (collectively referred to as “Personal Data”).
    5. You consent to this Notice's terms on the collection, storage, and use of the personal information you provide (including any changes thereto as provided by you) for any of the Involve Asia services that we offer.
    6. If you do not agree to be bound by all the terms of this Privacy Notice, Cookie Policy, Terms & Conditions, please exit and uninstall from your devices our Applications and do not access, use, and/or receive benefit from any of our Platforms and our collection of Services. Your continued use of any of our Platforms and Applications shall be deemed as consenting to all our terms in accordance with 2.2.
    7. We may, at any time and at our sole discretion, amend, and update this Privacy Notice. You are responsible for, among others, regularly reviewing this Privacy Notice.
    8. If there is any conflict between an English and Filipino version of this Notice, the English version shall prevail.
    9. Unless expressly provided herein or the context so requires, the words used in this Notice shall have the same meaning as assigned to them under the Data Privacy Laws.
    10. This Notice applies both within and outside of the Philippines. This Notice sets forth Involve Asia's minimum compliance standards, however, where local law and regulations require more stringent controls, then such stricter controls shall apply and must be strictly adhered to.
  3. DEFINITIONS
    1. “APPLICATIONS” shall mean the Application (downloadable from the URL https://app.involve.asia/advertiser).
    2. “COOKIES” are small pieces of information (including but not limited to small text files) that can be transferred by the web server and/or stored in a web browser, computer hard drive, cellular phone, tablet, other personal communication devices, applications or web tools (“Device”). Small graphic images such as “pixel tags” or “clear GIFs”, or small computer files, computer programs, and similar technologies that store information on your Device or collect information or help us to identify you, your account or Device can also be included on our Application. Cookies are widely used to remember you and your preferences, either for a single visit or multiple repeat visits.
    3. “DATA CONTROLLER” or “PERSONAL INFORMATION CONTROLLER” means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Notice, we are a Data Controller of your data.
    4. “DATA PROCESSOR” or “PERSONAL INFORMATION PROCESSOR” means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
    5. “DATA SUBJECT” is any living individual whose Personal Data is being processed pursuant to this Privacy Notice.
    6. “PERSONAL DATA” means any personal information and/or sensitive personal information as defined under the Law, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual from information either in our possession or likely to come into our possession.
    7. “USAGE DATA” is data collected automatically either generated by the use of the Application or from the Application infrastructure itself (for example, the duration of a page visit).
    8. “USER” is the individual using our Service via our Application. The User corresponds to the Data Subject whose Personal Data is protected by the Law.
    9. “SERVICE(S)” means the online affiliate marketing services offered by Involve Asia, including access to and use of the Applications and Network and any other service provided by Involve Asia.
    10. “WEBSITE” shall mean any world wide web owned by us or our licensor, and/or managed by us or our licensor, whether known now or in the future.
  4. COLLECTION OF PERSONAL DATA
    1. We have collected and will collect your Personal Data to be processed by us and/or on our behalf in the course of your present or future use, access, or any dealings with Involve Asia, its subsidiaries, affiliates, or associated companies.
    2. Your Personal Data enables us to achieve the Purpose (defined below in Clause 5) herein that is in connection with our business and Services. When you visit, use, or interact with our Application or the Website, or avail of our Services, we may collect certain information by automated or passive means using a variety of technologies, which technologies may be downloaded to your device and may set or modify settings on your device.
  5. DESCRIPTION OF PERSONAL DATA
    1. We collect several different types of Personal Data for various purposes to provide and improve our Service to you.
    2. You provide us with personally identifiable information such as your name, email address, and physical address through various media and/or forms, such as original, notarized, and/or stamped documents in print or copies in accessible, legible, and electronic format, as may be necessary. Other Personal Data that we do not expressly require of you but which you willingly provide to us are collected as well. The information we collect depends on the features, functionalities, products, and services that you request through our Applications. Such information, which may or may not include personally identifiable information, includes but is not limited to the following:
      • Name (First Name, Middle Name, and Last Name);
      • Identity Card Number;
      • Gender;
      • Date of Birth;
      • Email address;
      • Mobile Phone number;
      • Postal Address;
      • Nationality;
      • Preferred language;
      • Marital Status;
      • Income and Education level;
      • Fax Number;
      • Passport Number;
      • IP Address;
      • Images (still or recording);
      • Username, password, and login information for any account you may establish on our Website or Application or while using our Services;
      • Type of mobile device and its characteristics, including the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device;
      • Information as to your social media accounts, sites, products and services;
      • Contact information of friends or other people you would like us to contact;
      • Information you provide by interacting with us or accessing the Website or Application or availing our Services;
      • Location information, such as the real-time geographic location of the device on which you install and/or use our Applications, access our Website or avail of the Services;
      • Shopping behaviour and preferences, and a record of the purchases you make on our Websites or Application;
      • Clickstream data when you visit our Website, use or download our Applications or avail of our Services;
      • Data relating to your surveys, feedback, reviews and complaints;
      • Other details that you may submit to us or that may be included in the information provided to us by third parties;
      • Sensitive Personal Data;
      • Payment details and payment history (including payment card number, security code, expiration date, cardholder name, billing address and bank account details);
      • Personally Identifiable Information (PII) defined under international privacy laws or standards;
    3. The Personal Data provided by the Users is essential for the provision and enhancement of the Application, with the aim of providing an optimal user experience. As part of our ongoing efforts to improve the services, we may occasionally request additional Personal Data from Users, beyond what has been previously mentioned, through the Application and/or Website, subject to the User's explicit consent. Rest assured that we do not disclose this data to any third party, except as outlined within the provisions of this Notice.
    4. We reserve the right to verify the information and documents provided by Users using reliable sources. Involve Asia maintains the confidentiality and privacy of Users' information and only shares it with authorized parties as required by law or with the User's explicit consent. Involve Asia is dedicated to safeguarding Users' personal data in accordance with relevant data protection laws and regulations.
    5. We reserve the right to utilize your Personal Data for the purpose of communicating with you through newsletters, marketing materials, promotional content, and other information that may be deemed relevant and of interest to you. However, you maintain the option to unsubscribe from receiving any or all of these communications by following the provided unsubscribe link.
    6. Any Personal Data that you provide shall not be deemed as personal information if such information does not meet the definition of personal information under Republic Act No. 10173 or the Data Privacy Act of 2012.
    7. Upon registering with the Application, it is probable that we may periodically contact you to request updates or revisions to your Information. This is intended to ensure the accuracy and currency of your provided details.
  6. PURPOSES FOR COLLECTION OF PERSONAL DATA
    1. Involve Asia will only collect and process Personal Data about you when we have a lawful basis to do so. The primary purpose of collecting your information, including Personal Data, is to provide you with personalized access to Involve Asia and its various features, as well as for other lawful purposes as deemed necessary. It is important to note that if you choose not to provide consent for the collection of your Personal Data, it is possible that we may be unable to fulfill our contractual obligations to you. By "perform the contract," we are referring to the Terms of Use that govern your use of the Application. Consequently, your access to certain features of the service may be restricted or we may be unable to provide you with the service in its entirety.
    2. Involve Asia may use your Personal Data to perform the contract with you so as to:
      • Register you for membership at our Websites, Applications, and Services and to manage, maintain, and administer your account(s);
      • Manage your Offer(s), Programmes, or Campaigns;
      • Process, validate, confirm, verify, deliver, track, and maintain a record of your purchases (including by processing payment card transactions, handling refunds, and contacting you about your orders, including by telephone);
      • Respond to your questions and comments and provide customer support;
      • Communicate with you about our products, Services, offers, events, and promotions, and offer you products and services we believe may be of interest to you;
      • Manage your participation in our events, sweepstakes, and other promotions;
      • Enable you to communicate with us through our blogs, social networks, and other interactive media;
      • Publish your testimonials about Involve Asia, including on our Websites, blogs, and on social networks;
      • Tailor our services to suit your personal interests and the manner in which you use our Website, Applications, and Services;
      • Operate, evaluate, and improve our business and the Services we offer;
      • Manage, operate, administer, and provide you with as well as facilitate the provision of our Services;
      • Enhance our marketing communications and strategies for internal analysis;
      • Analyze how you use our Website, Applications, and Services;
      • Protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;
      • Prevent or investigate any actual or suspected violations, fraud, unlawful activity, omission, or misconduct, whether relating to your use of our Website, Application, or Services or any other matter arising from your relationship with us;
      • Store, host, back up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside of your jurisdiction;
      • Enforce any of our Terms of Use and Terms and Conditions of our Website and Applications;
      • Comply with applicable legal and regulatory requirements, industry standards, and our policies;
      • Respond to legal processes or to comply with governmental or regulatory requirements of any relevant jurisdiction;
      • Identify, verify, and authenticate;
      • Allow other users to interact or connect with you on the Website and Applications;
      • Protect personal safety and the rights, property, or safety of others;
      • Provide you with a more seamless customer experience;
      • Support research and innovation of our products and services;
      • Store and carry out data analytics processes;
      • Manage staff training and quality assurance;
      • Maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Website, Application, and Services;
      • Comply with Involve Asia's legal and regulatory obligations in the conduct of its business;
      • Allow third parties to contact you for advertising, promotional, or marketing campaigns conducted by any third-party entities;
      • Internally investigate, audit, or for security purposes;
      • Help us understand the performance of various Offers, Campaigns, or Programmes; and
      • Diagnose or fix technology or software problems.
    3. We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection unless processing of such Personal Data without your consent is permitted by law.
    4. We may combine the Personal Data we collect with publicly available information and information we receive from our parent, affiliate, or subsidiary companies, business partners, and other third parties.
  7. SOURCES OF PERSONAL DATA
    1. Involve Asia may obtain your Personal Data from the following sources including but not limited to:
      1. When you visit, access or use our Website, Applications, or Services;
      2. When you call or email us or communicate with us through social media or any interactive media;
      3. Interact with us via telephone, letters, fax, face-to-face meetings, social media platforms and emails;
      4. When you participate in our events or other promotions;
      5. When you provide us any Personal Data during the onboarding process, creating an account, filling up any registration forms, etc. on our Website, Applications, or for use of our Services;
      6. When you enter into any agreement with us or provide other documentation or information in respect of your interactions with us, or when you use our Website, Applications, or Services;
      7. From our affiliate or subsidiary companies, business partners, and other third parties;
      8. Directly from you or indirectly from your legal representatives, agents, and/or employer;
    2. The above does not purport to be exhaustive and sets out some common instances of when Personal Data about you may be collected.
  8. INFORMATION AUTOMATICALLY TRACKED WHILE USING THE APP OR SITE
    1. Usage Data

      We may also collect information that your browser sends whenever you visit our Service or when you access our Service by or through a mobile device (“Usage Data”). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

      When you access our Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device's unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

    2. Demographic and Related Information

      In order to deliver more targeted communications and promotions, we reserve the right to utilize additional sources of demographic and other pertinent information. This allows us to enhance the relevance and effectiveness of our communications with you.

      To monitor and analyze user behavior on the App/Site, as well as to continually improve our services, we employ various tools which provide valuable insights into user interactions and enable us to optimize our offerings.

    3. Tracking Cookies Data

      In our efforts to enhance the responsiveness of the Website and/or Applications for our Users, we may employ the use of cookies or similar electronic tools. These tools enable us to collect information and assign each visitor a unique and random number, known as a User Identification (User ID). This User ID allows us to gain insights into the individual interests of Users by analyzing their interactions on the identified computer. By continuing to visit the Website and/or Application, you are expressly agreeing to the utilization of cookies and similar technologies for the purposes outlined in this Notice.

      Cookies and other technologies are employed for the purpose of analyzing and optimizing our websites, as well as for marketing initiatives. It is important to note that our partners may also assign their own cookies to your browser. This process is beyond our control, and we cannot govern or regulate the activities of our partners in this regard.

      Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our service.

      You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service.

      Our policy on cookies is more comprehensively discussed below:

  9. COOKIE POLICY
    1. When you visit our Website, or use our Applications or Services, we may collect certain information by automated means, such as cookies and web beacons. Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website. The information we may collect by automated means includes:
      1. information about the devices you use to access the Internet (such as the IP address and the device, browser and operating system type);
      2. URLs that refer you to our Website;
      3. dates and times you accessed each page on our Website with click stream information and time stamp;
      4. information on actions taken on our Website or Applications or while availing our Services;
      5. a general geographic location (such as country and city) from which you access our Website, Applications or Services.
    2. The cookies used by our Website are solely associated with anonymous users and their computers and do not provide Personal Data on users. Some cookies are used by third parties to provide Involve Asia with data on the efficacy of its engagements functioning business and promotion.
    3. We use cookies to understand your usage of our Website, Applications and Services. The cookies used by our Website do not in any way collect Personal Data that could be used to identify a specific user. Furthermore, cookies are of a temporary nature, used solely to improve the efficiency of the last transmission and store your preferences.
    4. Please take note that by continuing to use our Website, Applications and/or Services, you are consenting to the use of cookies.
    5. You are not obliged to accept cookies. You may configure your browser to notify you of the reception of cookies and to prevent their installation on your device/computer. However, please note that if you do this you may not be able to use the full functionality of our Website, Applications or Services.
  10. WHAT WE DO NOT COLLECT

    We do not collect more than what is necessary. The only Personal Data, if any, that we collect comes from you. We collect only the minimum amount and kind of information necessary for our Services.

  11. DISCLOSURE OF PERSONAL DATA
    1. The information (including Personal Data) collected may be shared with our affiliates, and group companies to the extent required for our internal business and/or administrative purposes and/or general corporate operations and to any third-party service providers including marketing partners, and the User hereby consents to the same. We will take reasonable steps to ensure that these third-party service providers are obligated to protect your personal information and are also subject to appropriate confidentiality/non-disclosure obligations and they comply with the applicable provisions of the data protection laws. These entities, with whom we share the Information, may market to you as a result of such sharing unless you explicitly opt-out.
    2. The User consents to share Personal Data, including sensitive Personal Data, when it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offenses. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing the Terms of Use or for complying with the applicable laws and regulations. No Personal Data of an individual User such as name, contact number, email address, spending data, card details, etc. would be shared with any other User and/or third party unless explicitly approved by the concerned individual User himself/herself. We may also present Personal Data related to credit records, User spends, patterns, and User data tracked by us only in the form of aggregated statistics on data such as overall app usage by date, time, balances, etc. within our Website and/or Application or to our partners.
    3. By using the Application and providing Personal Data to us, Users agree and consent to the disclosure, transfer, storage, and processing of the Personal Data, including the sensitive Personal Data, by us in the Philippines and/or in other countries to its affiliates, group companies, and third parties. While our primary motive is to protect the disclosure of Personal Data (except in accordance with the provisions of this Notice) of Users, Users may note that countries where their Personal Data may be stored, may not have data protection laws similar to the countries where they are located.
    4. In our data-sharing activities, the following shall be observed:
      1. The amount of information that shall be collected and processed is defined.
      2. The information shall be provided only to the authorized recipients to date.
      3. The information shall only be shared with entities located in countries with data protection laws that are similar or comparable to Philippine data privacy laws.
      4. We may withhold or order to cease processing or sharing of data at any time if it deems that such processing or disclosure is contrary to Law or adversarial to our interests.
      5. We may share anonymized or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.
    5. We may disclose your Personal Data to:
      1. other subsidiaries, affiliates, and associates of Involve Asia;
      2. our employees, agents, authorized representatives, or intermediaries;
      3. other users, persons, organizations, companies, individuals, or entities who are part of our network;
      4. our service providers such as auditors, lawyers, company secretaries, printing companies, financial institutions, telecommunications companies, contractors, vendors etc.
      5. relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any statutory or governmental authority;
      6. any other party to whom you authorise us to disclose your Personal Data.
    6. In the event of a potential, proposed or actual sale of business, disposal, acquisition, merger or other reorganisation or restructuring of Involve Asia, your Personal Data may be required to be disclosed or transferred to a third party as a result thereof. You hereby acknowledge and consent to such disclosure and transfer and permit Involve Asia to release your Personal Data to such other third parties.
    7. Involve Asia is committed to complying with the Act, in particular, its policies as well as corresponding regulations, guidelines and orders. We do not sell or otherwise disclose personal information about you, except as described in this Privacy Notice.
  12. SECURITY OF PERSONAL DATA
    1. Involve Asia uses strict procedures, technical and physical safeguards and security features such as encryption and authentication tools to prevent accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use of your Personal Data as far as possible.
    2. Personal data provided to Involve Asia via our Website, Application or Services are protected during transit using appropriate encryption. We use encryption to protect certain of your purchase information while in transit. When personal data is stored by Involve Asia, we use computer systems with limited access housed in facilities using physical security measures.
    3. Data stored in cloud services is in encrypted form including when we utilize third party storage. The level of security of Personal Data which is kept in a non-electronic environment is also treated with strict procedures and means.
    4. Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.
    5. Your Personal Data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. While we cannot ensure that loss, misuse or alteration of data will not occur, we will make reasonable commercial efforts to prevent such unfortunate occurrences.
    6. You are strictly advised to keep your account username, password and details strictly confidential and not share that information with anyone. You should also sign off your account and close your browser window when you have finished your visit to our Website and Applications.
    7. We implement appropriate security measures to safeguard against unauthorized access, alteration, disclosure, or destruction of data, including accidental or intentional manipulation, and loss from unauthorized parties. These measures encompass internal assessments of our data collection, storage, processing practices, and security protocols. We employ suitable encryption and physical security measures to protect against unauthorized access to systems where personal data is stored. All Personal Data collected on the Involve Asia platform is securely stored within controlled databases. Access to these servers is password-protected and strictly limited.
    8. Our security measures undergo regular reviews and updates to align with technological advancements. While we take all reasonable steps to ensure the security of Personal Data, it is important to understand that no transmission of data over the internet or any other public network can be guaranteed to be 100% secure.
    9. We strive to comply with applicable data protection laws to safeguard User privacy and Personal Data. We have implemented physical, electronic, and procedural safeguards that align with the laws of specific jurisdictions to protect User Personal Data. By accepting the terms of this Notice, you acknowledge that the standards and practices we have in place are reasonable and adequate for the protection of your personal information.
    10. In the event of a breach of security, confidentiality, or integrity resulting in the unauthorized access or disclosure of your unencrypted electronically stored Personal Data, we will promptly notify you via email or any other feasible means without undue delay, to the extent consistent with the legitimate needs of law enforcement. We will take all necessary measures to investigate and remediate the breach, and restore the reasonable integrity of the data system.
  13. TRANSFER OF PERSONAL DATA
    1. We are very serious about providing a comparable level of protection for Personal Data should the information be processed or used outside Philippines.
    2. Involve Asia will only transfer your information overseas in accordance with the Data Privacy Laws.
    3. When we obtain Personal Data about you, we may process the information outside of the country in which you are located, and you hereby consent to the same. The countries in which we process the information may not have the same data protection laws as the country in which you are located. We will protect your information as described in this Privacy Notice.
  14. RETENTION OF PERSONAL DATA
    1. Your personal data will be retained in accordance with the provisions in this Notice, the Act, the relevant laws and regulations, the duration of your relationship with us and/or such period as may be deemed necessary for fulfillment of the purposes as stated in this Privacy Notice.
    2. Notwithstanding the foregoing and to the extent permitted by law, we may retain your data for fraud prevention or similar purposes required by laws.
  15. USE BY CHILDREN
    1. The Website, Application and Services are not intended for children under the age of 18 years.
    2. We do not knowingly collect or maintain any Personal Data or non-personally identifiable information from anyone under the age of 18 years nor is any part of our Website, Applications or Services directed to children under the age of 18 years. As a parent or legal guardian, please do not allow such children under your care to submit Personal Data to Involve Asia.
    3. In the event that Personal Data of a child under the age of 18 years in your care is disclosed to Involve Asia, you hereby consent to the processing of the child's Personal Data and accept and agree to be bound by this Notice on behalf of such child.
    4. We will close any accounts used exclusively by such children and will remove and/or delete any Personal Data we believe was submitted without any parental consent by any child under the age of 18 years.
  16. MARKETING AND PROMOTIONAL PURPOSES
    1. Upon subscribing to our services, you will receive marketing and/or promotional emails, notifications or calls from us, which include information on future events.
    2. If you do not wish to receive any promotional news content or calls, you may unsubscribe at any time by notice to us.
  17. THIRD PARTY WEBSITES
    1. Please be informed that this Privacy Notice applies solely to the Involve Asia Website, Applications and Services and does not apply to any third party websites you may access from links to other sites present on our Website or Applications.
    2. These sites may be operated by companies not affiliated or connected with Involve Asia and may have their own privacy notices and you are advised to read them. We are not responsible for the content of any links or websites not affiliated with Involve Asia.
    3. It is also important to exercise caution that these websites operate under their own distinct privacy statements, which are beyond our control. To further protect yourself, we recommend reviewing the privacy policies of these websites before providing any personal information. When you navigate away from our Website and/or Applications (which can be determined by checking the URL in your browser's address bar), any information you provide is subject to the Privacy Notice of the respective website operator. We cannot provide any representation or warranty regarding how your information is stored or used on third-party servers.
  18. DATA SUBJECT'S OBLIGATIONS
    1. It is necessary for Involve Asia to collect and to retain your Personal Data. Therefore, it is also obligatory for you to supply Personal Data to us in the most accurate manner. If you do not provide us with true and accurate Personal Data, we are unable to, process Personal Data on your behalf, for the purpose stated in Clause 5 herein, or effectively render our Website, Application and Services to you, and all relationships created or to be created between us may cease or be inoperative.
    2. In the event you may need to provide us with Personal Data relating to third parties, you confirm that you have obtained their consent or are otherwise entitled to provide their Personal Data to us and inform them to read this Privacy Notice at our website at https://involve.asia/.
  19. RIGHTS OF DATA SUBJECT

    Under the Law, you are entitled to the following data privacy rights:

    1. the right to be informed whether your Personal Data shall be, are being, or have been processed;
    2. the right to object to the processing of your Personal Data;
    3. the right to reasonably access your Personal Data;
    4. the right to dispute the inaccuracy or error in your Personal Data and have us correct it immediately and accordingly;
    5. the right to suspend, withdraw, or order the blocking, removal or destruction of your Personal Data from our records;
    6. the right to file a complaint with the NPC for any violation of your data privacy rights;
    7. the right to be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your Personal Data not in accordance with this Notice;
    8. and the right to data portability of your Personal Data.

    In respecting your data privacy rights, you may opt to tell us the following:

    To exercise your rights regarding access, correction, or deletion of the Personal Data you have provided, you may contact us via email:

    Email: [email protected]

    1. To request access to Personal Data

      You have the right to request access to your Personal Data processed by us by providing reasonable written notice. We shall be entitled to charge a fee (where permitted under the applicable law) for any data access request.

      Please note that we may decline to comply with your data access request if:

      1. you do not supply us with sufficient information to verify your identity;
      2. such access will constitute a violation of an order of court or any laws, regulations or rules;
      3. such access will disclose confidential commercial information;
      4. such access is regulated under other laws, regulations or rules.
    2. To request correction of Personal Data
      You have the right to request for correction and/or update of your Personal Data that is or may be inaccurate, incomplete, or outdated. Once we have sufficient information from you to deal with the request, we will correct your Personal Data within a period of 21 (twenty-one) calendar days. Where we are unable to do so within the said period, we will notify you of the soonest practicable time within which we can make the correction.
    3. To limit processing of your Personal Data
      You are entitled to limit the processing of Personal Data by expressly drawing the consent given previously, in each case, subject to any and all applicable legal restrictions, and contractual conditions and within a reasonable time period. Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose Personal Data where such collection, use, and disclosure without consent is permitted or required under applicable laws (e.g., other lawful criteria exist for the processing of personal information).
  20. YOUR PART IN PROTECTING YOUR DATA

    The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

    You agree that you too play a part in ensuring your personal data and the data of others are protected. By accessing our Website and/or Application and/or using our services, you declare, represent, and warrant that:

    1. You have been notified of the existence of, you have read, understand and agreed to our Privacy Notice, our Terms of Use and our Terms and Conditions;
    2. You absolutely agree with our Privacy Notice, Terms of Use and Terms and Conditions, and all of its contents such as but not limited to your representations and warranties, your agreement with and related waivers concerning our and our Partners' limitation of liabilities, and assumption of certain responsibilities in exercise of your data privacy rights;
    3. By accessing, benefitting from, using, and/or giving consent to our varied platforms, directly or indirectly, such as the latest official build of our Website and the latest versions of our Applications and/or through our Services, you agree to be bound to our Privacy Notice, Terms of Use and Terms & Conditions. You agree to have your data collected, corrected, transferred, stored, retrieved, used, retained, shared, deconstructed, and/or destroyed in the manner disclosed in our Privacy Notice, Terms of Use and our Terms & Conditions;
    4. You will keep yourself updated with any changes in our Privacy Notice, Terms of Use and Terms and Conditions, and your continued use of our Websites and/or Applications and/or Services indicates your agreement with any additions, changes, subtractions, or modifications thereto;
    5. You represent and warrant that all information that you provide to us are accurate, given in good faith, lawful, and true.
    6. (if any) During account creation (if any), information entered therein is true and correct to the best of your personal knowledge, and is not false, fabricated, misleading, for the purpose of any illegal activity, ill-will, nor information of persons, whether natural or juridical, other than yourself;
    7. (if any) During account creation (if any), should you enter information in representation of another person, whether natural or juridical, you warrant that you have obtained his/her/their consent and/or authorization, as the case may be, and such was willingly given, without duress, force, intimidation, or violence, and not through strategy or stealth;
    8. (if any) At the time of account creation and thereafter, all copies of certifications, licenses, permits, and various government and non-government issuances that you submit or upload to our database, whether in print or electronic format, are issued by the pertinent authorities acting within their proper lawful jurisdiction, genuine, unaltered, and valid; and not in any way altered through digital software, not physically tampered with prior to scanning into electronic format, not issued by a government or non-government authority outside of its proper jurisdiction, not fabricated, false, or a spurious copy, and not created, issued, or a product of/pursuant to any illegal activities, schemes, or methods;
    9. Should there be any genuinely suspicious activity and/or legitimately objectionable features in our Website and/or Application, instead of continuing the use of our Website and/or Application and/or using our services, you will alert or report us within twenty-four (24) hours from occurrence of said suspicious activity or encounter of the objectionable feature rather than proceeding with orders or continue use of our Website and/or Application and/or Service. You agree that your failure to alert us and/or continued access and/or use of our Website and/or Application and/or Service within said time period of said suspicious activity and/or objectionable features constitutes as your absolute waiver of any causes of action, claim, damages, and/or liability, of whatever nature, arising from such activity, incident, feature, and/or occurrence, and as against Involve Asia, its Board of Directors, officers and/or employees and/or its Partners;
    10. Should there be sufficient proof of a breach of your data privacy rights, as required under the Law, you will immediately inform us so that we could attempt to provide you with a proper response and/or reasonable redress within reasonable time from our receipt of our complete correspondence of your concern, compliant, or grievance;
    11. You access and/or use our Website and/or Application and/or Service in accordance with law, public order, public policy, morals, or good customs, and without any ill intent or malice against us, other users, and merchants;
    12. By submitting the required Personal Data to us, you consent to such collection, disclosure and use thereof. You hereby expressly waive and unconditionally release us from any and all liability, claims, causes of action, or damages, of whatever nature, arising from our legitimate use of the submitted Personal Data;
    13. You agree, warrant, and represent that you will absolutely assume all of your liabilities, roles, and responsibilities as a distinct, independent, and separate data controller of Personal Data of your own data subjects, as may be applicable and/or necessary. You therefore irrevocably hold Involve Asia, its Board of Directors, corporate officers, and/or employees and/or its partners harmless from any cause of action, damages, and/or liability arising from, incidental to, or simultaneous with any data privacy law breaches insofar as its own capacity as data controller and/or its own set of data subjects.
  21. DISCLAIMER
    1. This Privacy Notice is effective as of the date of its last modification and will remain in effect unless its provisions are changed in the future. Such a modified version will be in effect immediately after posting on this page dedicated to the Privacy Notice.
    2. We reserve the right to amend, update or modify this Privacy Notice from time to time without any prior notice to you. We advise that you check our website for the Privacy Notice on a regular basis. Kindly view our privacy notice on the website https://involve.asia/.
  22. CHANGES TO PRIVACY NOTICE
    1. This Privacy Notice is effective as of the date of its last modification and will remain in effect unless its provisions are changed in the future. Such a modified version will be in effect immediately after posting on this page dedicated to the Privacy Notice.
    2. We reserve the right to amend, update or modify this Privacy Notice from time to time without any prior notice to you. We advise that you check our website for the Privacy Notice on a regular basis. Kindly view our privacy notice on the website https://involve.asia/.
  23. MISCELLANEOUS
    1. These terms shall be governed by and construed in accordance with the laws of the Republic of the Philippines. The parties hereto submit to the exclusive jurisdiction of the courts of Manila City, Philippines.
    2. The terms set forth herein shall remain effective and shall remain binding upon you until and unless you discontinue any further use of the Applications and/or Websites and or Services provided by Involve Asia.
    3. To the extent permitted under the law, you agree to indemnify, defend, and hold Involve Asia, its affiliates, shareholders, directors, employees, agents, service providers, suppliers, subcontractors, successors, and assigns, harmless from and against any and all claims, demands, actions, causes of action, damages, costs, and expenses, including reasonable attorney's fees and other expenses of litigation, penalties, fines, damages, and losses, made by any third party due to or arising out of your breach of the Privacy Notice stated herein and the documents they incorporate by reference, or by your violation of any law or the rights of a third party.
    4. Involve Asia may subcontract any part or parts of the Services it provides to you at any time and may assign or novate any part or parts of its rights.
    5. Collecting any personally identifiable information from the Websites and/or Applications, including the use of communication systems provided on the Websites and/or Applications for any commercial solicitation purposes is not allowed. Distribution or publication of vouchers or codes, solicitation for any reason whatsoever to any users of the Websites and/or Applications and hacking or scraping the Websites and/or Applications are prohibited acts, which will be dealt with accordingly to the fullest extent available under the law.
    6. The Notice (and the respective amendments), and any undertaking you executed in relation thereto, shall constitute the entire agreement between you and Involve Asia. In the event of any conflict between these Terms and any other term or provision on the Websites and/or Applications the terms in this Notice shall prevail.
    7. If any of the terms shall be deemed invalid, illegal, or unenforceable, such term or condition shall be deemed not written and the remainder shall continue to be valid and in force.
    8. No delay or failure on the part of Involve Asia to enforce its rights or remedies under this Privacy Notice shall constitute a waiver on its part of such rights or remedies unless such waiver is set forth and confirmed in writing by its duly authorized representatives.
  24. ACKNOWLEDGEMENT AND CONSENT
    1. By communicating, engaging with Involve Asia or by accessing or using our Website, Services and Applications, you acknowledge that you have read and understood this Privacy Notice and agree and consent to the use, processing, disclosure and transfer of your Personal Data by Involve Asia as described in this Notice. You can withdraw your consent at any time by providing written notice of a reasonable time.
  25. INQUIRIES AND COMPLAINTS
    1. Should you require further information about the Personal Data we hold or the way in which your information is being collected, used or disclosed which are not answered by this Privacy Notice, please contact or write to our Data Protection Officer at:

      Contact Number: +6012-6050200

      Email: [email protected]

      Address: 18-01 & 18-03, Level 18 Menara MBMR, Jalan Syed Putra, 58000 Kuala Lumpur, Malaysia

  26. REASONABLE TIME FOR OUR RESPONSE AND LAWFUL INTERRUPTION THEREOF BY FORCE MAJEURE
    1. You agree with our terms for a response within a reasonable time; lawful interruption thereof; and force majeure in relation to the exercise of your data privacy rights.
    2. We shall exert our best efforts to address your concerns, complaints, or grievances, and these shall be examined with care, and professionalism, and within reasonable time from our receipt of your complete correspondence with us.
    3. Such reasonable time depends on the circumstances of said concern, complaint, or grievance, and shall be deemed lawfully interrupted by certain events beyond the control of any party herein such as but not limited to: acts of God such as natural calamities, typhoons, tornado, volcanic eruption; acts of political instability such as revolution, civil war, insurrection, civil disobedience, riot, terrorism, economic sabotage; the threat of spread of mandatorily reportable communicable and infectious diseases such as but not limited to COVID-19, government declaration of public health emergency measures such as national and/or local quarantines and/or other management/employee restrictions; acts of authorities whether lawful or unlawful; prolonged suspension or unavailability of public transportation, telecommunication, and electric utilities; and other force majeure events.
This Privacy Notice was last updated on 07 August 2024.