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 and process your personal data

When we process your personal data, we do so under the following legal bases and for the purposes set out below:

1. 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.
2. 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.
3. 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.
4. 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;
• 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;
• 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
5^th Floor Launchpad, Reliance corner Sheridan Streets,
Barangay Highway Hills, Mandaluyong City, 1554
cignaldataprivacy@cignaltv.com.ph