Privacy Notice

Who are we?

PT NOVENTIQ SERVICES INDONESIA with its offices at 1226, Philippines, City of Makati, Paseo de Roxas Avenue, Bel-air, 8767, Philam Life Tower, 24/F (hereinafter “NOVENTIQ”, "we" or "us"), acting as data user (data controller) respects and is committed to protect and safeguard your personal data. This Personal Data Protection Notice ("Privacy Notice”) explains how we collect and handle your personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) in instances when you are asked to submit personal data to us.

We will process your personal information in accordance with this Privacy Notice, the Data Privacy Act of 2012 (Republic Act No. 10173), and all relevant regulations, standards, code of practice and guidelines as may be prescribed from time to time.

What does this Privacy Notice cover?

This Privacy Notice applies to our public-facing website https://noventiq.ph/ and all included services available on this website or provided off-site by the controller. Some NOVENTIQ websites, apps, or online services may collect and use personal information about you in a different way and so will have a different NOVENTIQ Privacy Notice. We encourage you to look at the applicable Privacy Notice, available on said websites, apps, or online services. Our sites contain links to other websites not owned by NOVENTIQ and we do not control the content or privacy practices of those sites.

Our website and offerings are directed to people in their business or professional capacities. They are not intended for persons under 18 years of age. We do not knowingly solicit information online from, or market online to, persons under 18 years of age.

Please note, for purpose of this Privacy Notice, personal information means data or set of data that can identify an individual, such as name, address, telephone number, and email address. For what type of data we collect for a specific purpose see below.

What personal data do we collect and how do we intend to use it?

Data collected for concluding and executing contracts for the sale of goods or services

Data subject categories: representatives and employees of companies purchasing goods and/or services from the controller. Natural persons purchasing goods and/or services from the controller.
Type of data: Full name, email address, delivery address, phone number. Additionally, for companies: company name, VAT no. During the execution of an order, the following data may be processed: clickstream, Data on payment methods, identifiers of payment transactions, methods and terms of payment, IP address.
Purpose: concluding and executing contracts for the sale of goods or services.
Legal basis: fulfilment of a contract with the data subject.
Retention time: we will keep the data until the termination of the contract, plus the applicable prescription term. The following data (Full name, address, identifiers of payment transactions) will be retained pass this retention term and archived in order to comply with the minimum retention terms for financial and accounting records legislation.
Source of data: the data is provided by you directly.
Requirement to provide data and consequences of not providing: the fields are necessary for the conclusion and execution of the contract, not providing such data will result in failure to conclude and execute said contract.
Additional purpose: the data will be used for statistical purposes in order to better understand our customers and deliver high quality of services and goods.

Data collected for customer support

Data subject categories: employees of companies that require support, purchasing goods and/or services from the controller. Natural persons purchasing goods and/or services from the controller.
Type of data: Full name, email address, phone number, recording of communication, company name.
Purpose: customer support for ongoing contracts.
Legal basis: contract performance.
Retention time: we will keep the data until the termination of the contract, plus as long as needed to serve the purpose for which it was collected..
Source of data: the data is provided by you directly, or is obtained in the context of the conclusion and execution of the contract.
Requirement to provide data and consequences of not providing: the data is necessary for the customer support service, not providing such data will result in failure to provide said support.
Additional purpose: the data will be used for statistical purposes in order to better understand our customers and deliver high quality of services and goods.

Data collected for marketing purposes (contacting you via email or telephone for offerings of services, news or events registration)

Data subject categories: Natural persons that register or opt-in to get marketing communication from the controller or from our partners.
Type of data: name, email address, telephone.
Purpose: promoting our or our partners services and products.
Legal basis: consent. You can unsubscribe any time by clicking the unsubscribe link available in all marketing communication or contact us at the details mentioned below.
Retention time: we will keep the data as long as necessary to provide you with the information you subscribed for as long as needed to serve the purpose for which it was collected, unless the existing contract, legal claim or legal requirement justifies further processing.
Source of data: the data is provided by you directly through the subscription for our newsletter.
Requirement to provide data and consequences of not providing: the fields are necessary for subscription, and failure to provide this data will result in the inability to register for receiving marketing communications.

Data collected through webforms for events registration

Data subject categories: Natural persons that register to events hosted or facilitated by the controller.
Type of data: business contact details that might include name, email address, telephone number, company, role, industry.
Purpose: to register you for the specific event and provide you with the needed information to attend said event.
Legal basis: execution of a contract, consisting of participation in the event.
Retention time: we will keep the data as long as necessary to fulfil the purpose pursued.
Source of data: the data is provided by you directly by filling in the webform.
Requirement to provide data and consequences of not providing: some fields are marked necessary in our webforms in order to submit such forms; not providing such data will result in the inability to submit a form and register for the event.

Data collected for KYC purposes

Data subject categories: Beneficial Owners, Key Controllers, Directors, and Related Parties of companies purchasing goods and/or services from the controller.
Type of data: full name, citizenship, date of birth, manner of control over the controller’s client.
Purpose: know your client due diligence process.
Legal basis: generally we consider that we have both a legal obligation and a legitimate interest to conduct this diligence process (Anti-money laundering, and counter terrorist financing, trade sanctions).
Retention time: we will keep the data as long as necessary to fulfil the purpose pursued unless an ongoing legal claim, legal requirement or applicable rule – including but not limited to the applicable statute of limitations – justifies an additional retention time.
Source of data: We compile information from publicly available sources. These sources are in the public domain and are reasonably accessible or available to us, such as public websites, regulatory websites, open government databases, exchanges, and public registries.

Data collected and when you contact us directly via email, telephone or post:

Data subject categories: Natural persons contacting the controller via different communication channels;
Type of data: depending on the content and channel of your communication to us, this includes business contact details, content of your communication.
Purpose: to provide you with requested information and respond to your queries.
Legal basis: legitimate interest in providing the requested information.
Retention time: we will keep the data as long as necessary to fulfil the purpose pursued. Notwithstanding the other provisions we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Source of data: the data is provided by you directly, through interactions with our company and websites, and from publicly available sources of business-related information.
Requirement to provide data and consequences of not providing: not providing such data will result in no ability to obtain required information.

With whom we share your data?

We disclose your information to NOVENTIQ employees from the relevant teams, companies processing the data on our behalf (hosting providers, mail system provider, organizations providing maintenance services; entities providing services in the field of tax and legal services, subcontractors performing customer service and logistics tasks, providers of statistical, advertising and analytical services, payment service providers, independent third parties when this is necessary (auditors, lawyers, inspection agencies) or based on your choices and actions (as when you ask us to send you a shipment or letter using a third-party provider) or when you agree to share your data with our partners. Where necessary, your personal data may be transferred outside Philippines if any of our subsidiaries, service providers or strategic partners ("overseas entities”) who are involved in NOVENTIQ’s business are located in countries outside Philippines. We shall take reasonable steps to ensure that any such overseas entities are contractually bound not to use your personal data for any reason other than the purpose they are contracted by us to provide and to adequately safeguard your personal data. These overseas entities will treat your personal data as confidential, in accordance with this Privacy Notice and with all applicable data protection legislation and will process such personal data only for the purposes and within the terms set out herein.

We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claim, whether in court proceedings or in an administrative or out-of-court procedure.

What are your rights?

Right to withdraw your consent: You can unsubscribe any time by clicking the unsubscribe link available in all our marketing communication, change your preferences on the cookie consent tool or contact us at the relevant contact points indicated below.
Right to information and transparency: You have the right to be informed on the manner in which we process your personal data.
Right to access – You have the right to know what if any of your data we process and obtain a copy of it.
Right to rectification – You have the right to request us to rectify or complete your data, as the case may be, on the basis of an additional statement.
Right to restrict the processing – You can request us to restrict the processing of your personal data in certain cases.
Right to erasure (“right to be forgotten”) – You have the right to request and obtain the erasure of your personal data in some cases.
Right to object: you have the right to object at any time, under certain conditions, to the processing of your personal data.
Right to data portability – In certain cases you have the right to receive the personal data that you have provided us in a structured, commonly used and machine-readable format or to request we transfer it to another controller.
Right not to be subject to automated decision-making: We will not make decisions about data subjects based solely on automated processing.
Right to launch a complaint with the competent data protection authority at: National Privacy Commission (NPC), Address: 5th Floor Delegation Building, PICC Complex, Vicente Sotto Avenue, Pasay City, Metro Manila 1307, phone number: (02) 8234 2228, email: info@privacy.gov.ph.

You may exercise any of your rights in relation to your personal data by written notice to us, using contact details indicated below.

How do we safeguard your personal data?

We use a range of security measures to protect your personal information, which based on the specific data we process and the risk that the processing activity might pose to your rights and freedoms, might be:

Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services.
Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
Processes for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures in order to ensure the security of the processing.
Measures for user identification and authorization.
Measures for the protection of data during transmission.
Measures for the protection of data during storage.
Pseudonymization and/or encryption of personal data.
Measures for ensuring physical security of locations at which personal data are processed.
Measures for ensuring events logging.
Measures for ensuring system configuration, including default configuration.
Measures for internal IT and IT security governance and management.
Measures for certification/assurance of processes and products.
Measures for ensuring data minimization.
Measures for ensuring data quality.
Measures for ensuring limited data retention.
Measures for ensuring accountability.

How can you contact us?

Email: DPO.Philippines@noventiq.com

Address: 11226, Philippines, City of Makati, Paseo de Roxas Avenue, Bel-air, 8767, Philam Life Tower, 24/F

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please report it via the contact points provided in Speak UP Policy.

How do we keep this Privacy Notice updated?

We may amend this Privacy Notice from time to time and the updated version shall apply and supersede any and all previous versions. Please check our website for information on our most up-to-date practices.

The date at the bottom of this Privacy Notice shows when it was last updated.

September 6th, 2023