Data Privacy Policy
In this Policy…
Personal data refers to any information that identifies you as a person. As defined by the Philippine Data Privacy Act of 2012, this may be “sensitive personal information”.
Data privacy refers to the necessity to preserve and protect any personal data collected by an organization from being accessed by a third party.
This Data Privacy Policy aims to explain the following:
Your data privacy rights
Your data privacy rights are protected by the Philippine Data Privacy Act of 2012. This law states that you have the right to:
- Be informed. You must be advised if your personal data will be or has been processed. This includes the existence of automated decision-making and profiling in select transactions.
- Access. You have the right to reasonable access, upon written request, the contents of your personal data that were processed and the manner by which these were processed; the sources from which these were obtained; the recipients and reasons for disclosure, if any; date when your information was last modified; and information on automated processes where your information will be made as the sole basis for any decision that may significantly affect you.
- Rectify incorrect data. You have the right to correct any error in your personal data and, if warranted, request immediate rectification.
- Erase or block. You have, based on reasonable grounds, the right to suspend, withdraw or order the blocking, removal or destruction of your personal data from TFA’s filing system, without prejudice to TFA continuing to process personal data for commercial, operational, legal and regulatory purposes.
- Secure data portability. Where your personal data is processed by electronic means and in a structured and commonly used format, you have the right to obtain a copy of it from TFA for your further use.
- Be compensated for damages. You shall be compensated for any damage sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms.
- File a complaint. You may file a complaint or exercise your rights above by reaching out to our General Counsel in the contact details provided below.
What personal data we collect
We ask you for your personal data when you:
- Download resources from our website
- Send a comment or an inquiry through our website
- Subscribe to our newsletter
- Join our events
- Become our partner, vendor, supplier, employee or contractor
The personal data we collect from you may include the following:
- Name, designation, organization, and contact details
- Other information that you have directly provided us
The more information you volunteer (and the more accurate it is), the better we are able to assist you with your real estate inquiry.
We may also ask for personal data from other sources whom you have permitted to share your information with us. These sources may include your legal advisor, co-owners, business partners, government and other regulatory bodies, and other third parties.
It must be noted that this Policy does not apply to third party websites which have links to our sites. The processing of your personal data in a third party site is subject to their own Data Privacy Policy. TFA will not be responsible for the information collected from such sources, neither will TFA be liable for any loss or damage caused by the use of or reliance on such third party.
Where we use your personal data
We process your personal data based on your consent, legitimate business interest, and lawful processing. We use it only for:
- Providing our transaction and consultancy services to help you meet your requirements;
- Complying with applicable laws, regulations, directives, issuances by, or agreements and obligations of TFA to any competent authority, regulator, supervisory body, enforcement agency, exchange, court, quasi-judicial body, or tribunal;
- Identifying, investigating, and preventing financial crimes, including fraud, bribery, money laundering and terrorist financing, including but not limited to submitting reports to the Anti-Money Laundering Commission (AMLC) and other regulators;
- Enforcing and/or defending the rights of TFA before any agency, court, tribunal, quasi-judicial body;
- Recognizing other lawful or legitimate commercial or business purposes necessary for the performance of, or in relation to, a contract or service in which you are part of;
- When necessary or desirable in the context of an employer-employee relationship; and
- Enabling TFA to manage its business and ensuring that we are able to identify, measure, manage, and mitigate any risk that may come up.
We may use your information for other purposes necessary to provide other incidental services in line with your transactions.
Meanwhile, partnerships and corporate entities that TFA works with are expected to:
- Advise concerned people of the purpose/s of collecting personal data, including other relevant information and disclosure of the said data to TFA;
- Inform them of their data privacy rights; and
- Obtain the necessary consent and authority to disclose personal data of its directors, officers, employees, members, and other representatives to TFA, as mandated by the Data Privacy Act of 2012, its Implementing Rules and Regulations, and other applicable laws and regulations.
How we protect your personal data
TFA keeps your personal data in paper-based files and electronic records. While the processing of your personal data exposes you to financial, legal, regulatory, or reputational risks that may result from its unauthorized processing or disclosure, TFA is committed to protecting your privacy by:
- Maintaining physical, technical, and organizational safeguards to protect your personal data against loss, theft, unauthorized access, disclosure, copying, use, or modification
- Using a secured server behind a firewall, encryption, and other secured controls
- Limiting access on a need-to-know basis.
TFA takes responsibility for all your personal data in our possession. This includes information transferred to third parties who perform services on our behalf, whom we require to strictly adhere to our privacy policies and practices.
Personal data sharing and disclosure
We may disclose and share your personal data based on your consent, legitimate business interest, and lawful processing, to the following parties:
- TFA’s directors, officers, employees, duly authorized representatives, related companies, affiliates, and legal advisors;
- Third party service providers and vendors including encoding, printing and courier services; credit card processors; hosting vendors; and customer support providers who are obliged to keep your personal data confidential. They will have access to your personal data only as necessary to perform their requested function on your behalf, and only if their security and privacy standards are acceptable to TFA;
- Any authority, regulator, supervisory, enforcement agency, exchange, court, quasi-judicial body or tribunal;
- Professional advisers including accounting, tax, financial or legal counsel; or
- Anyone we consider necessary for purposes of providing you services and other lawful purposes mentioned above.
Privacy policy terms
TFA reserves the right to update or change sections of this Data Privacy Policy any time and without prior notice. We will exert reasonable efforts to reach out to our clients in case there are significant changes, but we highly encourage you to review this Policy every now and then.
If you have questions about this Data Privacy Policy, our data processing activities, or transactions made via this website, you may contact TFA’s General Counsel at (632) 8553-2995 or send an email to kristine.tolentino@tfa.ph.