LIVE EVENTS AND DIGITAL MEDIA CORP. PRIVACY POLICY
1. PRIVACY STATEMENT
Live Events and Digital Media Corp. (“LIVE PH”) aims to safeguard all personal data under its control and custody and to uphold the privacy rights of individuals from and about whom we collect and process such data in accordance with Republic Act No. 10173, or otherwise known as the Data Privacy Act of 2012 (“DPA”) and as reflected in this Privacy Policy.
LIVE PH shall undertake reasonable efforts to effectively notify affected individuals should there be amendments to LIVE PH’s Privacy Policy due to changes in the way we collect and process personal data including any disclosures to third parties and future developments in local and/or foreign data privacy regulations.
2. SCOPE
2.1. This Privacy Policy enumerates LIVE PH’s organizational policy in relation to the collection and processing of all personal data.
2.2. LIVE PH reserves the right to amend and/or modify its Privacy Policy to comply with any future developments in local and/or foreign data privacy regulations where applicable.
2.3. This Privacy Policy applies to all personal data processing activities conducted by LIVE PH, its subsidiaries and partners, including, but not limited to, the collection, use, storage, sharing and disposal of all personal data about their customers and employees.
3. DEFINITIONS
● Data Subject – is defined under Section 3(c) of the Data Privacy Act as any individual whose personal information is processed.
● Data Sharing Agreement – is defined as the disclosure or transfer to a third party of personal data under the control or custody of a personal information controller. The term excludes outsourcing, or the disclosure or transfer of personal data by a personal information controller to a personal information processor.
● Processing – is defined as any operation or any set of operations performed upon personal information including, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of data.
● Personal Information – is defined as any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.
● Personal Information Controller – is defined as a person or organization who controls the collection, holding, processing or use of personal information, including a person or organization who instructs another person or organization to collect, hold, process, use, transfer or disclose personal data on his or her behalf.
● Personal Information Processor – is defined as any natural or juridical person qualified to act as such under this Act to whom a personal information controller may outsource the processing of personal data pertaining to a data subject.
● Sensitive Personal Information – is defined as personal information (a) About an individual’s race, ethnic origin, marital status, age, color, religious, philosophical or political affiliations, beliefs or opinions, and trade union membership; (b) About an individual’s health, education, genetic and/or biometric data, sexual life and/or orientation, or any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings; (c) Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; (d) Specifically established by applicable local and/or foreign laws as classified;
● Personal Data - shall refer to all types of personal information, including those pertaining to agency personnel
4. COLLECTION AND USE OF PERSONAL DATA
4.1. Customer Personal Data
We collect personal data from customers/clients for whom we provide events design, execution and management services for the following purposes:
a) Compliance with applicable laws, rules and regulations;
b) Customer/client project assessment and account management;
c) Project contract preparation and execution;
d) Communications;
e) Customer/client billing and collection;
f) Event content, design, and concept pitch, output and presentation;
g) Financial services, accounting and reconciliation;
h) Business development, including, among others, the conduct of marketing/information campaigns relating to our complimentary services, offers/programs, and business analysis and research; and
i) The achievement of corporate objectives and business endeavors and compliance to applicable laws, rules and regulations.
4.2. Applicant and Employee Personal Data
We collect and process personal data from our applicants and employees for Administrative and Human Resource Development purposes as well as in compliance to applicable labor laws, rules and regulations, including, but not limited to:
a) Identity verification;
b) Company orientation and training;
c) Pre-qualification and post-qualification assessment;
d) Performance evaluation and career development;
e) Processing of employment compensation and benefits, including HMO coverage;
f) Internal Security, including facilities/asset access control;
g) Company asset accountability and supply/asset requisition;
h) Compliance to labor and other regulatory requirements;
i) For the protection of lawful rights and interests of the organization in internal administrative and court proceedings, or the establishment, exercise or defense of legal claims against prospectively malfeasant employees.
4.3. Suppliers and Service Providers
We collect and process personal data from our suppliers and service providers for the following purposes:
a) Project sourcing and coordination;
b) Contract preparation and execution;
c) Project documentation;
d) Supplier/Service Provider billing and payment;
e) Communication and requirements coordination;
4.4. Client Customers, Employees and Data Subjects
As we are an events management company, our clients also engage us to design and implement systems, platforms and/or processes for participant application, registration, provisioning and communication for and on their behalf. Considering the event-specific variety of the personal data we collect and process for and on behalf of our clients, it is our policy to ensure that our attendees are properly informed of the extent of personal data collected and processed about them and the purposes for such processing; and, when necessary, to obtain their consent. This includes the personal data to be collected and disclosed to our clients and data to be used by LIVE PH, among others, to:
a) To secure attendee access to our events;
b) To improve and personalize user experience in our virtual events platform;
c) To communicate with attendees regarding advisories, reminders, announcements, promotions, product placements, offers, invitations and other notifications;
d) To prevent illegal activity; and
e) To comply with our operational, audit, administrative, risk management processes, policies and procedures, the terms and conditions governing our products, services, and channels, LIVE PH's rules and regulations, legal and regulatory requirements of government regulators, judicial and supervisory bodies, tax authorities or courts of competent jurisdiction, as the same may be amended or supplemented from time to time.
We collect electronic and physical personal data through our registration booths, our website and social media profiles, and our digital platforms and/or mobile applications.
5. THE RIGHTS OF DATA SUBJECTS
LIVE PH fully recognizes that data subjects from and about whom we collect and process personal data are accorded the following privacy rights:
● Right to be informed
Our customers/clients, employees, suppliers and service providers have the right to demand and be informed of the details about how and why we collect and process their personal data including its sources, recipients, methods, disclosures to third parties and their identities, automated processes, manner of storage, period of retention, manner of disposal and any changes to such processing activities before the same is undertaken.
● Right to Object
They have the right to object to the sharing of their data. Should there be any changes in the information provided to them under this policy, they shall be informed of such changes and their consent thereto, where applicable, obtained before such changes are implemented.
● Right to withdraw consent anytime
They have the right to withdraw their consent to the processing of their personal data anytime subject to any lawful basis for which such data is processed other than by consent.
● Right to access
They have the right to have reasonable access to their personal data, upon demand and in a machine-readable and/or data portable format.
● Right to dispute/rectify
They have the right to review and amend their personal data as processed by the organization should there be any inaccuracies.
● Right to object/block/erase
They have the right to reject further processing of their personal data, including the right to suspend, withdraw, and remove their personal data in our control which are falsely collected or unlawfully processed.
6. POLICY ON THE COLLECTION AND USE OF PERSONAL DATA
It is the policy of LIVE PH to:
I. Adequately inform our customers/clients, employees, suppliers and service providers of their rights as data subjects. With respect to our events management services, we provide client data subjects with the proper terms and conditions for access to and use of our events platform. Clients, however, are responsible for informing their participants of the scope and nature of personal data processing we perform for and on their behalf;
II. Ensure that our customers/clients, employees, partners and service providers are fully and adequately informed of all processing activities performed by the organization with respect to their personal data including the scope, purpose and means used by LIVE PH for such processing and any changes thereto before the same is implemented;
III. Obtain the express, informed and properly documented consent of our customers/client, employees, suppliers and service providers, where applicable, to our data processing activities. Where the processing does not require consent as provided under applicable laws, we endeavor, nonetheless, to fully inform them of the bases of such processing other than consent;
IV. Ensure that our customers/clients, employees, suppliers and service providers have the facility to reasonably exercise their rights as data subjects and that the organization can adequately respond to such requests within reasonable time.
V. Ensure that our customers/clients, employees, suppliers and service providers have the facility to dispute inaccuracies in their personal data, to object to any changes in the manner and purpose by which their personal data is being processed, to withdraw consent where applicable, and to suspend, withdraw, block, destroy, or remove any unnecessary, falsely collected or unlawfully processed personal data;
VI. Ensure that the personal data obtained from our customers/clients, employees, suppliers and service providers are proportional, necessary and limited to the declared, specified and legitimate purpose of the processing;
VII. Ensure that the personal data of our customers/clients, employees, suppliers and service providers are retained for only a limited period or until the lawful purpose of the processing has been achieved;
VIII. Ensure that the personal data of our customers/clients, employees, suppliers and service providers are destroyed or disposed of in a secure manner;
IX. Ensure that our customers/clients, employees, suppliers and service providers have the facility to lodge complaints to LIVE PH relating to any violations of the rights of our customers and employees as data subjects and that such complaints are adequately and timely addressed.
X. With respect to personal data collected and processed from foreign sources, we ensure that their personal data is collected and processed in accordance with the applicable foreign law, if any.
7. PRIVACY GOVERNANCE
7.1 Data Privacy Officer
LIVE PH has appointed a Data Protection Officer (“DPO”) responsible for monitoring our compliance with any and all applicable foreign and/or local data privacy laws, rules, and regulations.
7.2 Contact Information
Our DPO is fully committed to protecting our customers’ and employees’ privacy rights. Should you have any concerns regarding LIVE PH’s privacy practices and policies, including requests for exercise of data subjects’ rights, you may reach the DPO through the following contact information:
8. PERSONAL DATA SECURITY POLICY
8.1 Storage Of And Access To Personal Data
It is our policy to store both paper-based and electronic personal data in a secure data center covered by appropriate data security standards. Transfers of personal data within and without the organization shall only be made in accordance with strict security protocols and under modes of transfer compliant with the appropriate data security standards.
8.2 Retention And Disposal Of Personal Data
We only retain personal data for a limited period or until the lawful and legitimate purpose of the processing is achieved. To that effect, we have established procedures for securely disposing files that contain personal data whether the same is stored on paper, film, optical or magnetic media, and computer equipment, such as disk servers, desktop computers and mobile phones at end-of-life.
9. MANAGEMENT OF THIRD-PARTY RISKS
a. Personal Information Processors
LIVE PH ensures that any processing of personal data outsourced to a third-party processor is covered by appropriate and enforceable contracts under terms and conditions compliant with the requirements of both local and/or foreign law, where necessary.
b. Personal Information Controllers
LIVE PH ensures that disclosures or transfers of personal data to controllers are governed by legally compliant data sharing agreements, where applicable. Likewise, individuals affected by such disclosures or transfers shall be duly informed and consent from them obtained, where applicable, before such data sharing activities are performed.
10. PERSONAL DATA BREACH
Personal Data Breach refers to a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed. Personal Data Breaches shall be subject to notification and remediation requirements.
11. HUMAN RESOURCE POLICY
LIVE PH requires its employees to undergo periodic and mandatory privacy and data protection training in general and in areas reflecting job-specific content. Likewise, it will ensure that all employees and personnel who collect and process personal data for us are adequately bound by strict confidentiality.