FRONERI Philippines Inc. Privacy Policy

Welcome to FRONERI Philippines Inc.’s privacy notice. FRONERI Philippines is part of the FRONERI Group of companies. You can find out more about our Group of companies on https://froneri.com.

FRONERI respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when interacting with us including when you visit our website and tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how FRONERI collects and processes your personal data when you interact with us including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

FRONERI is the controller and responsible for your personal data (collectively referred to as FRONERI, “we”, “us” or “our” in this privacy notice).

Contact details

• Full name of legal entity: FRONERI Philippines, Inc.
• Email address: [email protected]
• Postal address: FRONERI Philippines Inc, National Highway, Tibag, Pulilan, Bulacan 3005, Philippines
• Telephone number: (044) 326-3000 local 3000

You are afforded rights in relation to your personal information under the Data Privacy Act of 2012, including the right to access, correction, and objection to the processing, including the right to lodge a complaint with the National Privacy Commission.

Changes to the privacy notice and your duty to inform us of changes

[This version was last updated on 30 April 2024]

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
• Contact Data includes [billing address, delivery address, email address and telephone or mobile numbers].
• Financial Data includes [bank account and payment card details].
• Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
• Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website].
• Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
• Usage Data includes [information about how you use our website, products and services].
• Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, identity and expressions, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;
  • apply for job or apprenticeship;
  • create an account on our website;
  • become a customer, supplier or enter into other business relationships with us;
  • contact us with inquiry or complaint;
  • interact with us using social media;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

• Third parties or publicly available sources. We may collect information about you from other legitimate sources for the purpose of providing you with our products and services. Such sources include third party information aggregators, Froneri’s promotional partners, public sources and third party social networking sites with whom you have given consent for the disclosure of information relating to you and where otherwise lawfully permitted. Such information may include:

  • personal contact information; and
  • any personal information that is part of your profile on a third party social network (e.g. Facebook, Instagram, X (Twitter), Linkedin) and you allow that third party social network to share with us (e.g. name, email address, gender, birthday, city, profile picture, user ID, friend list). You can learn more about the information that we may obtain about you by visiting the website of the relevant third party social network.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

We may from time to time also rely on your consent as a legal basis for processing your personal data, although we generally only do this when sending direct marketing communications to you via email or text message or sharing your data with third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites). You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one grounds has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will ask you to set your preferences with respect to the marketing that you receive from us and from others and you will be able to change these preferences at any time by contacting us.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the FRONERI group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

These are small files that are widely used in order to make websites work more efficiently. Most web browsers allow some control of cookies through browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage or delete them from your computer, visit www.allaboutcookies.org.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly

On this website, we use:

FRONERI may, from time to time, engage in re-marketing, which means third-party vendors, including Google, may display R&R adverts on the internet, based on your prior interaction with the R&R website. To find out more about how Google uses any data it collects please visit https://policies.google.com/technologies/ads

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary (below)
• External Third Parties as set out in the Glossary (below)
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

This means that we may retain your personal information for a period of 10 years after your last interaction with us. When the personal information that we collect is no longer required, we destroy or delete it in a secure manner.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are explained at the end of this notice. If you wish to exercise any of the rights set out at the end of this notice, please contact us. Under certain circumstances, you have rights under data protection laws in relation to your personal data.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the FRONERI Group acting as joint controllers or processors and who are based in the Philippines, outside the Philippines who are based in the United Kingdom, EU and outside the EU (typically in the USA) and provide IT and system administration services, centralized Group services (such as customer support or marketing), any products or services you have requested and undertake leadership reporting.

External Third Parties

• Service providers acting as processors based in the Philippines and outside the Philippines who are based in the United Kingdom, EU and outside the EU (typically in the USA) who provide IT and system administration services;
• Third party brand owners who own the intellectual property rights in the brands of the products we manufacture and sell in the Philippines and outside the Philippines acting as processors or joint controllers who require reporting of processing activities in certain circumstances or who may need access to data to provide products, services or marketing information;
• Professional advisers acting as processors or joint controllers including lawyers, bankers, broker, auditors and insurers based in the UK, EU and outside the EU (typically in the USA) who provide consultancy, banking, legal, brokerage, insurance and accounting services;
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances;
• Customers of ours (and their audit providers) acting as processors or joint controllers based in the Philippines who require reporting of processing activities in certain circumstances (for example relating to the products we manufacture and supply to them for onward sale);
• Third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites);
• Third parties for marketing purposes where you have consented to this;
• Credit reference and fraud prevention agencies, crime prevention and law enforcement agencies and regulators acting as processors or joint controllers based in the United Kingdom who require reporting to prevent fraud or other criminal offences in certain circumstances;
• Service providers and agents (including their sub-contractors) acting as processors in the Philippines and outside the Philippines, who provide market research, marketing and advertising services to us or for and on our behalf;
• Any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
• Another organization if we sell or buy (or negotiate to sell or buy) any business or assets;
• Another organization to whom we may transfer our agreement with you; and
• Government departments where reporting is mandatory under applicable law.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.