Collection and Use of Personal Information

INTRODUCTION

Ayala Land Inc. and its subsidiaries (collectively referred as â€œAyala Landâ€, â€œweâ€, â€œusâ€or â€œourâ€) recognize the importance of protecting your Personal Data. This statement is one way of sustaining your trust in our company, our products and our services. Our privacy statement describes how we collect, protect and manage information from you through our websites, information systems and processes.

Ayala Land respects the confidentiality of Personal Information and is committed to comply with Philippine Data Privacy Act of 2012. We value data privacy rights and makes sure that all personal information collected from our customer, vendors, partners, employees, associates and other stakeholders, are processed in adherence to the general principles of transparency, legitimate purpose and proportionality.

This Privacy Policy explains:

What information we collect and why we collect it
How we use that information and to whom we may disclose it
The choices available for you to manage your personal information
How we safeguard your personal information

By providing Ayala Land with your personal information in the use of any of our products and services as described in this Privacy Policy, you have explicitly authorized and consented to our collection, use, access, transfer, storage and processing of said personal data.

PERSONAL INFORMATION WE COLLECT

Personal information is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.

PERSONAL INFORMATION As part of our dealings with you , we may collect your personal data including but not limited to:
- Your name, gender, civil status, date of birth, address, telephone or mobile numbers, email address, mailing address, proof of identification and any other information relating to you which you have provided us in submission of any form as a result of our interaction with you
- Your credit history, bank account and credit card information that you provide us in availing of our products and services
- Your employment history, education backround, resume and income information when you apply for a job with us
- Information about your visit and use of our websites including cookies, IP Addresses, your navigation behavior inside our website , length of stay that are processed by our website analytics
- Your work related information regarding your company, your ownership and participation when you apply for vendor accreditation.
COLLECTING PERSONAL INFORMATION We may collect and store your Personal Information in a variety of ways:
- When you purchase or avail of any of our product and SERVICES
- When you interact with our customer, face agents or specialist, through email, phone,chat services or face to face meetings.
- When you register, create or apply for an account through any of our digital medium (i.e website, facebook , twitter etc.)
- When you provide personal information for your inquiries, requests, and complaints
- When you respond to surveys, marketing promotions, and other initiatives
- When you submit a job application
- When you visit, browse and use any of the services on our website
- When we receive references from third parties or our business partners (i.e when you have been referred by them)
- When you submit your personal information to us for any other reason
PERSONAL INFORMATION OTHER THAN YOURS When you disclose to us another personâ€™s personal information (i.e your dependent, spouse, children and/or parents) you attest that consent has been obtained from that person to disclose and process personal information in accordance with this policy.

USE AND DISCLOSURE OF PERSONAL INFORMATION

USES OF YOUR PERSONAL INFORMATION Ayala Land collects, uses and discloses your Personal Infromation for the following purposes:
- Provide you with product and services that you have requested, including customer support
- Enhance your customer experience by delivering product services that match your preference and needs
- Communicate relevant services, advisories including responses to your queries, requests and complaints
- Provide information about our products and services which may be of interest to you.
- Comply with the requirements of the law and and legal proceedings such as court orders; comply with legal obligation or to prevent imminent harm to public security safety or order
- To prevent, detect and investigate crime, including fraud and money-laundering, and to analyze and manage other commercial risks;
- Process information for statistical, analytical and research purposes
OTHER USES BY NATURE OF OUR DEALINGS Aside from the general uses mentioned previously, we may use your personal information depending on your dealings with us in any of the following manner:
1. WHEN YOU INQUIRE OR PURCHASE A PROPERTY
  - To conduct appropriate due diligence checks
  - To register your inquiry and for follow up
  - To prepare all necessary sales documentation and any other documentation as may be requested
  - To perform all financial processing related to the sale such as set up of downpayment, amortization or financing
  - To manage all administration of unit turn over activities
  - To communicate all advisories and changes in relation to the sale
  - Any other purpose relating to any of the above.
2. WHEN YOU APPLY TO BECOME A MERCHANT OR TENANT IN ANY OF OUR PROPERTIES FOR LEASE
  - To conduct appropriate due diligence checks
  - To register and process your application
  - To prepare leased out documentation and any other documents as may be required
  - To perform financial transactions such as rental payments
  - To communicate any advisories, or changes in terms and condition related to your lease contract
  - Any other purpose relating to any of the above.
3. WHEN YOU ARE A VENDOR, A PROSPECTIVE VENDOR OR A CONTRACTOR
  - To evaluate your proposal and to conduct orresponding backround checks
  - To perform accreditation on your viability as a vendor
  - To communicate with you matters relating to required products and services
  - Any other purpose relating to any of the above.
4. WHEN YOU APPLY FOR EMPLOYEMENT OR BECOME OUR EMPLOYEE
  - To process your application including any of the following:
    1. Background check
    2. Conduct Testing and personality check
    3. Medical Check-up and clearance
    4. Collect information about your suitability for the position
  - To administer benefits and payroll processing
  - To organize training and development
  - To assess your performance
  - Any other purpose relating to any of the above
5. WHEN YOU ARE OUR SHAREHOLEDER
  - To administer the relationship such as identification verification including identity of your nominated proxy
  - Communicate the companyâ€™s performance including products and services as well as changes in polices, terms and conditions through various medium applicable
  - Any other purpose relating to any of the above
DISCLOSURE OF YOUR PERSONAL INFORMATION
1. We may disclose your personal information to the following as reasonably necessary depending on the product and service concerned:
  - Our Employees and officers
  - Professional advisers such as lawyers and auditors
  - Insurers and credit providers
  - Banks, credit card companies and their respective service provider
  - Suppliers or subcontractors, third party service providers , consultants that have been contracted by Ayala Land to provide financial, technical, architectural, administrative services such as information technology, payroll, accounting, sales admintration, procurement, training and other services
  - Any third party businesses offering goods and services or sponsor contest or other marketing and promotional programmes;
2. We may disclose your personal information to any of the following:
  - member of our group of companies this means our subsidiaries;
  - our ultimate holding company Ayala Corp and all its subsidiaries;
  - joint venture and alliance parthers;
  - insofar as reasonably necessary for the purposes set out in this policy.
3. We may disclose your personal information:
  - to the extent that we are required to do so by law;
  - in connection with any ongoing or prospective legal proceedings;
  - in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk;
  - to the buyer or prospective buyer of any business or asset that we are contemplating to sell or area selling
  - to any person who we reasonably believe may apply to a court or other competent authority for disclosure of such personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of such personal information.
4. Any company with which we share information about you for the above purposes is contractually required to comply with confidentiality standards, undertake to respect any individual's right to privacy and comply with the Data Privacy Act. We also require that these organisations use this information only for our purposes and follow our reasonable directions with respect to this information. This includes organizations which handle or obtain Personal Data as service providers for Ayala Land.

INTERNATIONAL DATA TRANSFERS

CLOUD SERVICES Information that we collect may be stored and processed in and transferred between any of the countries in which we make use of cloud services (i.e. office 365, amazon web services, salesforce) in order to enable us to use the information in accordance with this policy.
INTERNET Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

RENTENTION AND DISPOSAL OF YOUR PERSONAL INFORMATION

We will retain documents (including electronic documents) containing your personal data:

to the extent that we are required to do so by law;
if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Thereafter your personal information shall be disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public

ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

ACCESSING YOUR PERSONAL INFORMATION You may instruct us to provide you with any personal information we hold about you. Provision of such information will be subject to the supply of appropriate evidence of your identity
- We may withhold personal information that you request to the extent permitted by law.
- You may instruct us at any time not to process your personal information for marketing purposes
- In practice, you will either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
UPDATING YOUR PERSONAL INFORMATION

If the personal information that we hold about you needs to be corrected or updated, Ayala Land shall make all reasonable effors to ensure that data collected is current, complete and accurate. If you to access and update your personal data, you may send the request to alidataprivacy@ayalaland.com.ph or get in touch with respective customer support of the product or services that you have engaged with.

As part of our security measures, we will contact you and conduct the necessary verification measures to process your request. Once we have implemented the necessary correction we shall then notify you that your request have been process

WITHDRAWAL OF CONSENT If you wish to withdraw your consent given for any or all purposes set out in this Policy, you may send your detailed request to alidataprivacy@ayalaland.com.ph. Depending on the nature of your consent withdrawal, Ayala Land may not be in a position to continue to provide our products and services to you.

PROTECTING YOUR INFORMATION

PROTECTING INFORMATION YOU SUBMIT ONLINE We take precautions to protect your information. When you submit sensitive information via any of our official website(s), information is protected both online and offline. Wherever we collect sensitive information (such as credit card data), this is passed on our payment gateway which encrypts and transmits to us in a secure way. All our critical websites undergo security scanning penetration testing to reduce our websitesâ€™ vulnerability against cyber security attacks. While we employ all necessary precautions to safeguard you information, the Internet is not 100% secure so we cannot guarantee that information we collect or store will be protected from all unauthorized access and thereby used in a manner that is not inconsistent with this Privacy Policy.
HOW WE SAFEGUARD YOUR PERSONAL INFORMATION We maintain physical, technical and organizational safeguards to protect your personal data against loss, theft, unauthorized access, disclosure, copying, use or modification. We also put in effect safeguards such as:
- Using secured servers behind advance threat protection appliances, firewalls, encryptions and other security tools
- We limit access of your personal information to those who are qualified and authorized to process them. All such persons, wherever they are located, are required by us to protect the confidentiality and privacy of your personal data in a manner consistent with our privacy policies and practices. We are responsible for all personal data in our possession, including information transferred to third parties performing services on our behalf.
- We undergo regular security vulnerability and penetration testing of our infrastructure to ensure your data is always protected.

THIRD PARTY WEBSITES

Our websites may contain hyperlinks and details of third party websites . We have no control over, and are not responsible for, the privacy policies and practies of third parties. We therefore advise you to study their privacy policy. Once you leave our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

COOKIES AND SIMILAR TECHNOLOGIES

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes, after which the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

MANAGEMENT AND SECURITY

A Data Privacy Officer for Ayala Land and corresponding Compliance Officers of Privacy for our subsidiaries have been appointed per affected subsidiaries to to manage and safeguard the handling of your Personal Data compliant with the Philippine Data Privacy Act of 2012 or RA 1017 and this Policy. Ayala Land Management is committed to ensure that its Privacy Management Progam is constantly reviewed, monitored and enhanced. Ayala Land regards personal data breaches very seriously.

UPDATES TO THE POLICY

Ayala Land will amend this Personal Data Privacy from time to time. Ayala Land may also update this policy to apply changes due to new laws and regulation affecting the data privacy act, changes in our business operations and environment. Any updates of changes will be posted on Ayala Land main site with a date stamped so that you are informed of the latest Policy update.