Data Privacy
PRIVACY NOTICE AND DATA PRIVACY CONSENT
FORM
Cignal TV, Inc.
(“Cignal TV”) respects your fundamental right to privacy and we commit to take
great care in safeguarding your personal data. Throughout your use of our
services, we collect and maintain some basic information about you. In
accordance with applicable privacy laws, we share with you the general
principles that govern how we collect, use, and share your personal data, as
well as our privacy practices.
Why we collect your personal data
When we process your
personal data, we do so under the following legal bases and for the purposes
set out below:
A. We process your
personal data to perform our obligations under contract with you.
·
To create and nurture a
relationship with you, so that we can continuously provide you with our services. For
example, when you apply for our products and services, we collect personal data
about you that will allow us to validate your identity and credit history for
purposes of billing and collection of fees for the products and services that
you avail from us.
B.
We process your personal data based on our legitimate interest to function
effectively as a business, but we only do so when your interests and fundamental rights or freedoms do not override our
legitimate interest. +
·
To continuously improve
our business and operations. For example, we analyze your use of our products and services to help
us manage your account, provide customer care activities, investigate and
resolve your service-related requests and concerns, monitor the quality and
security of our technology, train our staff, and plan for future growth. We do this so that we can
continue to provide you with the best experience for the products and services
that you avail from us.
·
To continuously improve
our products and services. We collect, use, process, and analyze your use of our products and
services so that we can understand how to improve them for your benefit. Our
analysis may include some sensitive information about your usage, such as your
historical locational information which we determine based on an analysis of
the places where you may have used our products and services. In
all cases, we ensure to aggregate and anonymize this information so that you are never
identified as an individual.
·
To understand your needs
and preferences so that we can serve you better. We process data to determine your usage
profile by maintaining a record of the products and services that you avail
from us, and by analyzing other activities such as when you participate in our
market research initiatives, when you visit and transact in our stores, and
when you visit and use our websites and mobile apps such as www.cignal.tv and www.cignalplay.com. We do so in order to
gain a better insight about the kinds of offers that would be relevant to your
preferences.
·
To manage the security
of our business operations. We may process your personal data to conduct IT security operations, to
manage our assets, to ensure your fair use of our products and services, and
for business continuity, disaster recovery, and audit purposes.
C. We process
your personal data as you avail of our products and services so that we may be
able to create and offer better products and services for you, including
through direct marketing.
·
To send you offers,
recommendations and promotions. We process your usage
profile to send you customized offers and promotions through your contact
details using channels such as SMS, voice calls, and e-mail. This includes
location-based offers that are exclusively available in areas that you may
frequent.
·
To elaborate your usage
profile.
We may also collect personal information about you from third-party sources
such as our subsidiaries, affiliates, and business partners, to whom you have
also given your consent for them to share your information with us. We
create this enhanced usage profile about you solely to get a deeper
understanding of your preferences so that we can send you even better targeted
product recommendations, special offers, and promotions.
D.
We process your personal data to comply with legal requirements.
·
To assist public
authorities.
We generate statistical insights based on your usage of our network and
facilities to assist public authorities in planning for healthcare, disaster
management, and other similar initiatives meant for public benefit. When
we can, we aggregate and anonymize this information so that you are never
identified as an individual.
·
To comply with legal
requirements. We
run credit scoring programs and
initiatives, including but not limited to, providing information to the Credit
Information Corporation in accordance to Republic Act No. 9501 and the Credit
Information System Act. We may also
perform other required personal data processing or disclosure to meet other
relevant legal and regulatory requirements.
When we disclose your
personal data
In some instances, we
may be required to disclose your personal data to our agents, subsidiaries,
affiliates, business partners and other
third-party agencies and service providers as part of our regular business
operations and for the provision of our products and services.
This means we might
share your information with:
•
Our service
providers, contractors, and professional advisers who help us provide our
products and services. This includes partner companies, organizations, or
agencies, and their sub-contractors. For example: sales dealers, distributors
and installation contractors, our couriers for bill delivery, our customer
contact centers for our pre- and post-sales hotline operations and payment
processing partners;
• Our
subsidiaries and affiliates with whom you have also signed-up with. We do so
only for the improvement of each
other’s legitimate business and operations. For example: we share
information with each other about your usage profile so that we can create new
offers that bundle our products and services into a single subscription;
•
Other
companies to whom you have also given consent for us to share your information
with. For example, when you sign-up for products and services offered by
other companies, they may request for information from us in order for them to
validate your identity; and
•
Law
enforcement and government agencies, but only when
required by laws and regulations and other lawful orders and processes.
In these cases, we
ensure that your personal data is disclosed on a confidential basis, through
secure channels, and only in compliance with applicable privacy laws and
regulations. We will never share, rent, or sell your personal data to third
parties outside of Cignal TV, except in special circumstances where you may
have given your consent for, and as described in this statement.
For a list of our
partners, please visit https://cignal.tv/territorypartners
How we protect your personal data
The integrity, confidentiality, and security of your personal data are
important to us. That’s why we strictly enforce our privacy statement within
Cignal TV and have implemented technical, organizational, and physical security
measures that are designed to protect your information from unauthorized or
fraudulent access, alteration, disclosure, misuse, and other unlawful
activities. These are also designed to protect your information from other
natural and human dangers.
We also put in effect
the following safeguards:
- We keep and protect your information using a secured server behind a firewall, encryption and security controls;
- We keep your information only for as long as necessary for us to (a) provide the products and services that you avail from us, (b) for our legitimate business purposes, (c) to comply with applicable laws, and (d) for special cases that will require the exercise or defense of legal claims, and for a maximum retention period of ten (10) years from your service's permanent deactivation;
- We restrict access to your information only to qualified and authorized personnel who are trained to handle your information with strict confidentiality;
- We undergo regular audits and rigorous testing of our infrastructure’s security protocols to ensure your information is always protected;
- We promptly notify you and the National Privacy Commission, when sensitive personal data that may, under the circumstances, be used to enable identity fraud are reasonably believed to have been acquired by an unauthorized person; and
- We let you update your information securely to keep our records accurate.
What
your choices are
You are afforded certain rights in relation to your personal data under the Data Privacy Act of 2012 (Republic Act No. 10173). You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
- Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.
- Request a rectification of your personal data: this right entitles you to have your personal data corrected if it is found to be outdated, inaccurate, or incomplete.
- Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, such as in cases where your personal data is no longer necessary to achieve the legitimate business purpose of its use or processing.
- Request the restriction of the processing of your personal data: this right entitles you to request that we only process your personal data in limited circumstances, including with your consent.
- Request portability of your personal data: this right entitles you to receive a copy of personal data that you have provided to us (in a structured, commonly used and machine-readable format). This includes requests for us to transmit a copy of such personal data to another company, on your behalf.
You moreover have a right to object to the processing of
your personal data, such as in cases when we process your personal data for
purposes related to direct marketing.
To the extent that the
processing of your personal data is based on your consent, you have the right
to withdraw such consent, exercise the foregoing rights, or otherwise manage
your privacy preferences by (a) logging in your account portal located at our
website (b) contacting our customer service representatives through email or
telephone (c) contacting our Data Privacy Officer through the contact details
provided below. Please note that this will not affect the lawfulness of the
processing that was carried out before you withdrew your consent or Cignal TV’s
right to continue parts of the processing based on other legal bases than your
consent. If, however, we have not provided you with another legal basis
justifying the processing of your personal data in this privacy statement, we
will stop the processing and delete your personal data.
In some instances, we
may request for supporting documents or proof before we effect any requested
changes to your personal data.
If, despite our
commitment and efforts to protect your personal data, you believe that your
data privacy rights have been violated, we encourage and welcome individuals to
come to Cignal TV first to seek resolution of any complaint. You have the right
at all times to register a complaint directly with the National Privacy
Commission or to make a claim against us with a competent court (either in the
country where you live, the country where you work or the country where you
deem that data privacy law has been infringed).
Cignal TV Data
Protection Officer
5th Floor Launchpad, Reliance
corner Sheridan Streets,
Barangay Highway Hills, Mandaluyong City,
1554
cignaldataprivacy@cignal.com.ph