Data Privacy Consent

Introduction

Century Properties Group Inc. (CPGI) and our subsidiary, value your privacy by providing appropriate measures in protecting and managing your personal data. Our Privacy Policy follows, and is consistent with, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), other issuances of National Privacy Commission (NPC), as well as other relevant laws of the Philippines.

Personal data refers to all types of personal information, sensitive personal information and privileged information. Personal information refers to "any information, whether recorded in a material from or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual".

This Privacy Notice articulates how we process (meaning, how we collect, use, share, retain and dispose) and protect your personal data. It also tells you what steps you can take if you want us to change how we use your personal data, or if you want us to stop using your personal data.

Our Purpose for Processing your Personal Data.

To allow us to comply with the our corporate policies to its employees as well as with regulatory requirements being observed by CPGI as an employer, developer, controller, processor and third party, it is important that CPGI collects, uses, stores and retains your personal data when it is reasonable and necessary for a declared and specific purpose.

In general, we are using your data for any of the following purposes:

For Customers/Client:

• When you inquire about or purchased a property:
  • To conduct appropriate credit investigation to evaluate the credit risk associated to your financial obligations to CPGI;
  • To facilitate the sale and the turnover of a particular unit which necessarily includes the preparation of all documentation leading to the transfer of title, and perform all financial processes (reservation fees, amortization, handover fees, etc.) associated to your purchased.
  • To execute contract or provide information/services concerning the trading, brokerage, leasing, management and other incidental operations of real estates;
  • To update our records and keep your contact details and billing address up to date;
  • To provide safety and security to the unit owners, tenants and employees of tenants/unit owners; and;
• When you apply to become a tenant or merchant in any of our properties for lease:
  • To evaluate the interest of a party in a commitment to lease a space;
  • To conduct appropriate credit investigation to evaluate the credit risk associated to your financial obligations to CPGI;
  • To prepare lease contract and other documentations required and necessary in the consummation of the contract;
  • To perform all relevant financial transaction such as processing of security deposits, advanced rental payments, monthly rental payments and other incidental charges included in our contract;
  • To ensure safety and security to our unit owners, tenants and employees of tenants/unit owners;
  • To communicate any advisories, notice, or changes in the terms and condition related to your lease contract.
• For you to provide reviews in our products and services;
• For you to subscribe/unsubscribe to our e-newsletters;
• To generate statistical insights;
• To conduct research and analysis (through surveys or polls) in order to improve customer experience/satisfaction;
• To respond to specific complaints, inquiries, requests or to provide requested information;
• To provide customer care activities, monitor our quality and security, and provide services timely and efficiently; and,
• To notify and update you (through call, text or email) about our complimentary, commercial and promotional advertisements, loyalty and rewards offers, exclusive invites, discounts, surveys, and other direct marketing that we deemed relevant and beneficial to you based on your preference and interest initially provided to us or made aware of, with which you can opt-out anytime should you prefer not to receive these notifications.

• To conduct appropriate due diligence checks;
• To evaluate your proposal including your manpower, technical and operational capacity;
• To assess the viaibility of your proposal and process your accreditation;
• To communicate any decision on such proposal and issue a letter of award together with the contract; perform any other action as may be necessary to implement the terms and conditions of our contract
• To comply with CPGI’s obligations under law and as required by government organizations and/or agencies such as, but not limited to, the following: NPC, BIR, HDMF or Pag-IBIG, PhilHealth, SSS and so on;
• To comply with legal and regulatory requirements or obligations; and,
• To perform such other processing or disclosure that may be required under law or regulations.

Types of personal data we collect

The types of personal data that we will collect from you depends on the particular purpose and/or position for which you are submitting an application.
The common type of data collected by CPGI from you, generally includes the following:

• Basic personal information, such as full name, nickname, home addresses/billing address/shipping address, e-mail address, employment information, telephone, other personal contact numbers, username and password;
• Sensitive personal information, such as age, nationality, marital status, gender, health, education and government issued identification document which includes, but not limited to identity (ID) cards, licenses, social security number;
• Employment record, such as educational background, employment history, certifications, trainings attended, resume and income information of your previous jobs; and
• Financial details such as credit history, bank account, credit card, and debit card information you have provided as a result of our transaction.

Please note that you are responsible for ensuring that all such personal data you submit through this website is accurate, complete and up-to-date.

Our Method of Collection

We collect data when you:

• Submit a job application;
• Submit a proposal and/or business-related documents;
• Fill-out our forms and submit necessary documents;
• Submit information through any form on our digital platforms or contact us through any of our social media accounts;
• Purchase any of our properties, products, or avail of services and promos;
• Respond to surveys, promotions, and other marketing and sales initiatives;
• Provide personal information in relation to inquiries, requests, and complaints
• Subscribe to our newsletter by indicating your email address; and,

Web Analytics in our Website

This website engaged Google Analytics, a third-party service to analyze the web traffic data for us. This service use cookies or web beacons.

Cookies are small files that our website puts on your PC to store info about your preferences. Cookies can improve your browsing experience by allowing our website to remember your preferences or letting you avoid signing in each time you visit our website. If you don't want our website/mobile application to store cookies on your PC, you can block cookies. But blocking cookies might prevent some pages from displaying correctly, or you might get a message from our website/mobile application letting you know that you need to allow cookies to view that our website/mobile application.

Data generated is not shared with any other party. For you to fully enjoy your visit and browsing experience,
only non-identifiable web traffic data are collected and analyzed, including:

• Your IP address,
• The search terms you used,
• The pages and internal links accessed on our site
• The date and time you visited the site,
• Geolocation,
• The referring site or platform (if any) through which you clicked through to this website
• Your operating system, and
• Web browser type.

Use the options in your web browser if you do not wish to receive (a) cookie(s) or if you wish to set your browser to notify you when you receive (a) cookie(s). Click on the "Help" section of your browser to learn how to change your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features of this website.

Links to third-party websites

From time to time, we will provide links to third-party web sites, or advertisements which contain links to third-party sites. These links are provided as a service to you and we do not provide any personal data to these websites or advertisers, and therefore, we will not accept responsibility for their privacy practices. These sites are operated by independent entities that have their own privacy policies which you should also review CPGI’s Privacy Policy does not apply to such other sites or to the use that those entities make of your information. CPGI has no control over the content displayed on such sites, nor over the measures, if any, that are taken by such sites to protect the privacy of your information.

Sharing of your Data

As a general rule, we are not allowed to share your data to third party except in limited circumstances as noted below. By giving your consent, you authorize CPGI to disclose your personal data to accredited/affiliated third parties or independent/non-affiliated third parties, whether local or foreign in any of the following circumstances:

• As necessary for the proper execution of processes related to the declared purposes in this Privacy Policy.
• The use or disclosure is reasonably necessary, required or authorized by or under law (such as for criminal investigation, as requested by court of law).

This means we might provide your personal data to the following:

• Our affiliates, subsidiaries, partner companies, organizations, or agencies including their sub-contractors or prospective business partners that act as our service providers and contractors;
• Law enforcement and government agencies;
• Geolocation,
• The referring site or platform (if any) through which you clicked through to this website
• Your operating system, and
• All third parties, as noted in Annex A, with which we share this personal data are required to use your personal data in a manner that is consistent with this Privacy Policy.

However, these companies may only use such personal data for the purpose(s) disclosed in this Privacy Policy and may not use it for any other purpose.

How we protect your personal data

We take reasonable steps to make sure that your personal data we collect, use or disclose are accurate, complete, and up-to-date. We strictly enforce our Privacy Policy and we have implemented technological, organizational and physical security measures to protect your personal data we hold from loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction. We put in effect safeguards such as the following:

• We keep and protect your personal data using a secured server behind a firewall, deploying encryption on computing devices and physical security controls.
• We restrict access to your personal data only to qualified and authorized personnel who hold your personal data with strict confidentiality.
• We reveal only the last four digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
• Any personal data that you provide on this website is initially processed and stored by Century Properties. Using a secured connection, only authorized Century Properties Group personnel can then access and download your personal data from this website.
• It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign-off when finished using a shared computer.

Where and how long do we keep your personal data?

Century Properties reserves the right to retain your personal data in our files located in the Philippines under certain circumstances such as when your personal data may be necessary to resolve disputes, or if Century Properties is required to do so by law or in the good faith; provided that such action is necessary to comply with a legal obligation and/or protect and defend the rights or property of Century Properties or its affiliates. If Century Properties is required to retain any portion of your personal data for such purposes, it shall use reasonable efforts to limit such data to what is necessary to accomplish the particular purpose.

If there are changes in our Privacy Policy

From time to time, it may be necessary for CPGI to change this Privacy Policy. If we change our Privacy Policy, we will post the revised version here and will take effect immediately, so we suggest that you check here periodically for the most up-to-date version of our Privacy Policy. Rest assured, however, that any changes will not be retroactively applied and will not alter how we handle previously collected personal data without obtaining your consent, unless required by law.

How you can access, correct and update the personal data we have about you?

To exercise your rights which include right to access, modify, erase and object to processing your personal data within a reasonable time after such request or should you have any inquiries, feedbacks on this Privacy Policy, and/or complaints to CPGI, you may reach us through our "Contact Us"/"Customer Service" menu in this website, through a written letter or through an email to our Data Protection Officer (DPO).

Our contact details are as follows:

• Data Protection Officer Century Properties Group, Inc.
• 21st floor, Pacific Star Building Sen. Gil Puyat Cor. Makati Avenue, Makati City
• Office: TELEPHONE NUMBER loc. 793-5500
• Email address: Daniel.delacruz@century-properties.com

You may also lodge a complaint before the National Privacy Commission (NPC). For further details, please refer to NPC’s website: https://privacy.gov.ph/mechanics-for-complaints/.

Our decisions to provide such access or consider any request for correction, erasure and objection to process your personal data as it appears in our records are always subject to any exceptions under applicable and relevant laws and/or the DPA, its IRR and other issuances of NPC.

To cover for the cost of verifying a request for information and locating, retrieving, reviewing and copying any material requested, we may charge you minimal and reasonable fees based on administrative costs we incurred.

This Privacy Policy was last amended on March 2018