Privacy policy

OUR PRIVACY COMMITMENT

We value and respect the privacy right of our customers as Data Subjects under Data Privacy Act of 2012. The objective of this policy is to disclose how the company collects, uses, retains, and dispose the personal information of our customers. We provide this policy outlining our practices and security measures to ensure to the Data Subject that appropriate guidelines are in-place in handling their personal information. As such, we encourage you to read these terms carefully. By visiting our stores, browsing our online and mobile app platforms and by accessing the services we offer, you acknowledge that you have read and understood this Privacy Policy.

Our company shall review and update this Privacy Policy in case there is a change in data processing to align with regulatory requirements and industry best practices, revamp of the system to adapt with new technologies and protocols, or to comply with government and regulatory requirements, among other legitimate purposes.

As Data Subject, our company will ensure that you will be notified if changes in the Privacy Policy is extensive and will cause undue intrusion into your privacy.

DEFINITION OF TERMS

To have a better understanding of this Policy, the following words shall be defined as follows:

1. “Surplus” – shall refer to Surplus Marketing Corporation.

2. “Data Subject” – refers to an individual whose Personal and Sensitive Personal Information is collected, used, shared or otherwise processed;

3. “DPA Legislation” – shall refer to the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its implementing rules and such issuances related thereto.

4. “Personal Data” – any data, whether true or not, from which an individual person can be identified or ascertained; or from the data and other information which we may access to. It includes “personal information” and “sensitive personal information” as defined by the DPA Legislation.

5. “Online” – shall refer to Surplus engagement in social media and mobile applications.

WHEN AND HOW DO WE COLLECT PERSONAL DATA FROM YOU:

We may collect personal data from you in the following instances:

· When you visit our store and request customer related, pre and post transaction services.

· When you carry out transactions through online such as purchasing our products, queries about our products, customer service and other services.

· When you join our Viber community, visit, browse, interact in any of Surplus Social Media platform.

· To process your application or accommodate your request.

WHAT DO WE COLLECT FROM YOU:

We may collect the following information when you purchase Online or in our stores:

· Full name

· Email Address

· Contact number.

· Delivery or shipping Address.

· Loyalty or Rewards Card number, if applicable.

· Credit card number

· Signature

· E-wallet or Bank account name and number.

HOW WILL WE USE YOUR PERSONAL DATA:

No other personal information will be collected apart from what is required. Your personal data may be used or processed for any or all the following purposes:

· To render services to you, such as but not limited to, addressing your inquiries, feedback or concerns, processing your transactions with us;

· To provide you with updates on our products, services, and promotions.

· To conduct analytics and service related activities to improve our goods and/or services;

· To comply with applicable laws and our internal audit, financial and risk management procedures;

· To carry out legitimate business purposes.

Your personal information will be processed as long as your account is active and will be retained as required. Disposal of your personal information regardless of media are made in a secure manner that would prevent further processing, unauthorized access, and disclosure.

DISCLOSURE AND TRANSFER OF PERSONAL DATA

With your full consent, there may be cases where we may need to disclose or entrust your personal information to any of the following:

· To our parent company, subsidiaries, affiliates, employees, contractors, authorized personnel, and partners (herein collectively referred to as “Service Group”).

· Accredited third- party service providers such as but not limited to technology partners, payment processors, payment gateway service providers, financial institutions you chose when paying for your purchase, logistic providers and courier services;

· Such other party you authorize us to disclose your personal data.

Any personal information entrusted with such parties shall also be covered by the appropriate agreement contract, security requirements and security checks and only for the purpose of carrying out the above mentioned legitimate business purposes.

OUR COMMITMENT TO PERSONAL INFORMATION SECURITY

Surplus ensures the security and protection of your personal information against risk of data loss, unauthorized access and disclosure, alteration, and unlawful processing. Aside from establishing policies, rules, procedures and guidelines, our company also ensures all information are secured and protected within the scope of the organization. Our company also has undertaken procedures to conduct Privacy Impact Assessment to evaluate and manage the impact of privacy of a particular project, program, and process. Our company also ensures that a Personal Data Breach Management is in place.

Our company uses various appropriate and reasonable measures to safeguard your personal information, such as the following:

1. Organizational measures: appointment of Data Protection Officer, access control policy,

security awareness training, among others.

2. Physical measures: security on data centers, card storage, biometric devices, among

others.

3. Technical security measures: encryption, anti-virus software, among others.

USE OF COOKIES

Our website and its mobile application use cookies. Cookies are text files containing small amounts of information which are automatically downloaded to your computer or device when you visit a website. Cookies send data back to the originating website on each subsequent visit. Cookies are useful to you because they allow a website to recognize your device and browsing habits in order to give you a seamless and smooth browsing experience. We will not use cookies to collect personally identifiable information about you.

YOUR RIGHT AS A DATA SUBJECT

As data subject you have the right to be informed, to object, to access, to rectify, to erasure or blocking, to damages, to data portability and to complain in relation to your personal information under the Data Privacy Act of 2012. If you wish to correct or update your personal information, we may ask some information in order to verify and ensure the identity to avoid unwanted disclosure of personal information. We have included here contact information that can be used to voice clarifications and complaints relative to your personal information. Any complaint should be made in writing, clearly state the material facts, specify your contact information, and include supporting evidence.