Data Privacy Policy
Introduction
We, at MarCoPay Inc. (“MCP”), know the importance of your personal data privacy. We adhere with the requirements of all relevant privacy and data protection laws, particularly the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations. To this end, we are committed to ensure that any Personal Data you share with us is secured and protected. This Privacy Policy is designed to help you understand how we collect, use, store, share, manage, and protect your Personal Data.
2.    What We Collect
When you download MCP’s Mobile Application (“Mobile App” or “App”) and sign up to become a user, we will collect your Personal Data that are necessary to prove your identity and access the services we deliver through the Mobile App. Any information we collect is used to provide and improve the delivery of our services. In particular, we may collect the following Personal Data:
2.1    Personal Information and/or Sensitive Personal Information 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, such as your name, gender, civil status, date and place of birth, personal telephone and/or mobile numbers, personal email address, present and permanent addresses, family background, proof of identification (government-issued IDs and/or licenses), specimen signature or biometrics (fingerprint, face recognition, etc.), photo, and any other information relating to your identity;

2.2    Employment information such as your occupation, employer’s name, position/rank, date hired, and employment history;

2.3    Income information such as your basic salary and other income; and

2.4    Bank information such as your depositary bank, account name, account number, branch of account, and account currency.

2.5    For additional security, we may also collect the following information:

2.6    Device information. We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number), when you use our Mobile App.
2.7    Log information. When you use our services or open your account, we may automatically collect and store certain information in server logs. This may include:
    Details of how you used our services, such as your transaction history;

    Internet protocol (IP) address;

    Device event information such as crashes, system activity, and hardware settings; and/or

    Cookies that may uniquely identify your user account.
 

2.8    Location information. When you use a location-enabled device, we may collect and process information about your approximate location, like the global positioning system (GPS) signals sent by a mobile device 
3.    Why We Collect Personal Data
3.1    We collect your Personal Data and other information to facilitate your transaction needs and to effectively provide our products and services to you. In particular, we are using your information to:

3.1.1    Provide, maintain, and improve our services, including the specific features or functions of the Mobile App that you choose to use;

3.1.2    Develop new products, services, functions and features related to the Mobile App;


3.1.3    Abide by any safety, security, public service or legal requirements and processes; and

3.1.4    Generate statistical and analytical data for research and development purposes.

3.2    We also collect your Personal Information and/or Sensitive Personal Information to comply with the (Know Your Customer) KYC requirements of our partner financial institution, the Bangko Sentral ng Pilipinas (BSP), and Anti-Money Laundering Act (AMLA), among others.
4.    How We Collect Your Personal Data
We collect your Personal Data through forms fillable by print, online, video chat, and/or submissions through our Mobile App. Our Mobile App may request access to your device camera and other image capturing platform to complete your user application and verify your identity. We may also collect and verify your employment and/or income information from our partners, subsidiaries, and affiliates.
5.    Who Do We Share Your Personal Data With
5.1    Your Personal Data may at times be viewed or accessed for the purpose of resolving a problem, address support-issues, check suspected violation of MCP’s Terms of Service, or as may be required by law. You are responsible for maintaining the confidentiality and security of your user registration and password.

5.2    MCP may share your Personal Data to our affiliates, subsidiaries and/or third-party service providers. We will ensure that the parties who will have access to your Personal Data are obligated to maintain its security and confidentiality, and will use the same only in accordance with our instructions and under the terms of a Data Sharing Agreement that can demonstrate reasonable and appropriate safety measures to ensure the privacy and protection of your Personal Data.

5.3    We may also disclose your Personal Data to comply with legal requirements, such as submission of regulatory compliances and requirements to appropriate government agencies, compliance with a subpoena or similar legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

5.4    With your consent, we may also share your Personal Data with our affiliates, partners, and subsidiaries to facilitate your transactions with them through the Mobile App.

5.5    Aggregated information may be used to analyze performance or otherwise improve our services, but it will be aggregated and anonymized to prevent public disclosure of your Personal Data. We may therefore, share aggregated, non-personally identifiable information publicly and with our business partners. 
6.    How we store and protect your Personal Data
6.1    We take reasonable precautions to keep your stored Personal Data secure and protected. We employ organizational, managerial, electronic, technical, and physical security measures in order to protect your Personal Data from breaches that may result in accidental or unlawful destruction, or accidental loss, alteration, or unauthorized disclosure or access.

6.2    We restrict access to your Personal Data to only MCP employees, contractors, and agents who need to know such information (and only to the extent necessary) for its processing in order to provide you with our services. The aforementioned persons are subject to strict contractual confidentiality obligations and may be disciplined if they fail to meet these obligations.

6.3    Your account information is protected by a password. It is important that you protect your account from any unauthorized access by choosing your password carefully and by keeping your password and device secure, such as by logging out after accessing our Mobile App or your account. If you suspect any compromise to the security of your account, please change your password and contact us immediately at dpo@marcopayinc.com.

6.4    In the event that MCP is involved in a merger, acquisition or asset sale, the entity to which your Personal Data will be transferred (“Resulting Entity”) will continue to maintain the confidentiality and protection of your Personal Data pursuant to this Privacy Policy (and any updates hereto).  In the event that your Personal Data is to be subjected to another privacy policy, the Resulting Entity will notify you accordingly of the new privacy policy that will be applicable to you. 
7.    How Long Do We Retain Your Personal Data
7.1    We will retain your Personal Data for as long as your account in MCP remains active and retention is necessary to support the delivery of our services, or as may be required by law, whichever comes later.

7.2    We also retain log files for internal analysis purposes. These log files are generally stored for a brief period of time, except in cases where they are used to improve service functionality or security, or where we are legally obligated to retain them for a longer period of time. We also retain information from accounts disabled by reason of violation of any Terms of Service, for at least Three (3) years to prevent repeat abuse or violations or defend against potential allegations. 
8.    Your Rights Under the Data Privacy Act
8.1    As a data subject, or a person from whom MCP collects, processes and stores information, you have certain rights under applicable laws. We feel it is important that you are aware of and understand these rights as they apply to you. In particular, you have the following rights under the Data Privacy Act:
8.1.1    Right to be informed. You have the right to be informed whether your Personal Data shall be, are being, or have been processed, including the existence of automated decision-making and profiling.

8.1.2    Right to access. Upon demand, you have the right to reasonable access to the contents of your Personal Data that were processed, sources from which those were obtained, and names of recipients of your Personal Data, among others.

8.1.3    Right to object. You have the right to shall have the right to object to the processing of your Personal Data, including processing for direct marketing, automated processing or profiling.

8.1.4    Right to blocking or erasure. You have the right to suspend, withdraw or order the blocking, removal or destruction of your Personal Data from our system.

8.1.5    Right to rectify. You have the right to dispute the inaccuracy or error in your Personal Data and have it corrected immediately and accordingly, unless the request is vexatious or otherwise unreasonable.

8.1.6    Right to data portability. You have the right to obtain a copy of your Personal Data in an electronic or structured format.

8.1.7    Right to file a complaint. You have the right to file a complaint for any inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your Personal Data. 
9.    Changes to the Privacy Policy
9.1    MCP reserves the right to update this Privacy Policy in accordance with any changes in the applicable laws and implementing rules and regulations, personal information collection and use practices, the features of the Mobile App, or advances in technology. We encourage you to periodically review the latest version of this Privacy Policy to stay informed on how we protect your Personal Data.

9.2    By using our MCP web and mobile applications, you are consenting to the collection, use, disclosure and processing of your Personal Data as described in this Privacy Policy. 
10. Access and Change of Personal Data
If you wish to update the Personal Data you have previously provided, or to exercise any rights to the processing of Personal Data that you may have under the Data Privacy Act of 2012 and related laws and regulations, please contact our Data Protection Officer at dpo@marcopayinc.com, or you may write to:
Attention: Data Protection Officer
MarCoPay, Inc.
8th floor Three/NEO Bldg.
3rd Avenue corner 30th Street, E-Square I.T. Park,
Crescent Park West Bonifacio Global City
Taguig City 1634 Philippines 
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