Avodah is committed to complying with the Data Privacy Act of 2012 (Republic Act 10173) of the Philippines. This Privacy Policy Statement specifies how Avodah collects, uses processes and discloses your personal data. It also sets out the measures that we put in place with regards to personal data protection.

I. COLLECTION OF PERSONAL DATA

“ Personal Data ” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, employment information and financial information.

We collect Personal Data about you in the ways listed below:

You provide your Personal Data to us

We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:

1. complete a user profile or registration forms (such as your name, contact information and other identification information where needed);

2. provide information to assess your eligibility to provide services (such as your National Certificate number from TESDA);

3. interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);

4. verify your identity through various means (such as social media logins, submission of  selfie images or independently verified payment card information);

5. fill up demographic information in surveys (such as your age, gender, and other information you may volunteer such as your marital status, occupation and income information);

In certain circumstances, you may need to provide your Personal Data in order to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. Failure to provide such Personal Data, under such circumstance, may constitute failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with you, as the case may be.

When our services are used

Personal Data may be collected through the normal operation of our Apps, Websites and Services. Some examples are:

1. your location (Service Locale)

2. feedback, ratings and compliments;

3. transaction information (such as payment method and distance travelled);

4. information about how you interacted with our Apps, Website or Services (such as features used and content viewed);

5. personal data you enter in messages when you use our in-app communication features; and
   
   

When you provide Personal Data of other individuals to us

In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, you may add them as your emergency contact. If you provide us with their Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Policy.

Personal Data of minors

As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to Avodah. In the event that such Personal Data of a minor is disclosed to Avodah, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Policy and take responsibility for his or her actions. 

II. USE OF PERSONAL DATA

We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

Providing Services and Features

• to consider and/or process your application/transaction with us or your transactions or communications with clients via the Services;

• to manage, operate, provide and/or administer your use of and/or access to our Services and our Platform, as well as your relationship and user account with us;

• to manage, operate, administer and provide you with as well as to facilitate the provision of our Services, including, without limitation, remembering your preferences;

• to tailor your experience through the Services by displaying content according to your interests and preferences, providing a faster method for you to access your account and submit information to us and allowing us to contact you, if necessary;

• for identification and/or verification;

• to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;

• to allow other users to interact or connect with you on the Platform, including to inform you when another User has sent you a private message or posted a comment for you on the Platform;

Safety and Security

• to protect personal safety and the rights, property or safety of others;

• using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;

• to screen the service provider as well as the user before enabling their use of the application;

• to use device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities; and

• to detect, prevent and prosecute crime.

Customer Support

• to respond to, process, deal with or complete a transaction and/or to fulfill your requests for certain products and services and notify you of service issues and unusual account actions

• to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf

• to share your data with third party for fulfillment of your transaction with us or refunds;
  

Legal Purposes

• to enforce our Terms of Service or any applicable end user license agreements;

• to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on Avodah or on its related corporations or affiliates;

• to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;

• to prevent or investigate any actual or suspected violation of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us.

• to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves Avodah as a participant or involves only a related corporation or affiliate of Avodah as a participant or involves Avodah and/or any one or more of Avodah related corporations or affiliates as participant(s), and there may be other third party organizations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organization or a portion of an organization or of any of the business or assets of an organization.

We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign, regulatory, government or other authority.

Research and Development

We may use the Personal Data we collect for auditing, research and analysis and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with Avodah’s Services;

Market and Promotions

• to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;

• to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyze how you use our Services, to improve our Services or products and/or to enhance your customer experience;

• where you give us your prior consent, for marketing and in this regard, to send you by various modes of communication such as postal mail, email, location-based services or otherwise, marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom Avodah may collaborate or tie up with) that Avodah (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future.

If you wish to unsubscribe to the processing of your Personal Data for marketing and promotion, please click on the unsubscribe link in the relevant email or message, alternatively, you may also update your preferences in our App settings.

As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.

III. DISCLOSURE OF PERSONAL DATA

Avodah do not sell, distribute or lease Personal Data or information that you provide or which Avodah otherwise comes by to third parties unless required by law, or with your permission. We may however disclose or transfer Personal Data or information for the purposes of rendering our services to you and this may include disclosure to any professional, third party service providers to us, who are formally engaged by us to help us make available and provide the Website and the Avodah Service.

IV. RETENTION OF PERSONAL DATA

Avodah will not retain Personal Data for longer than is necessary and will take reasonable steps to destroy or permanently de-identify Personal Data.  
 

Avodah will take all the steps reasonably necessary to ensure that Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of Personal Data will take place to an organization or a country unless there are adequate controls in place.  In the event that Avodah becomes aware of a security breach which Avodah may believe has resulted or may result in the unauthorized access, use, or disclosure of Personal Data, Avodah will promptly investigate the matter and notify the User of such breach.  However, Avodah will not be responsible for any unauthorized use of Personal Data by third parties which is attributable to factors beyond the control of Avodah.

V. COOKIES AND ADVERTISING ON THIRD PARTY PLATFORM
When you visit our Website, we may also automatically record information that your browser sends whenever you visit a website. This data does not identify you as an individual and may include:

1. Your computer's IP address;

2. Browser type;

3. The pages you visit on our Website; and

4. The time spent on those pages, items and information searched for on our site, access times and dates, and other statistics.

This information is collected for analysis and evaluation in order to help us improve the Website and Avodah Services. This data is collected anonymously and will not be used in association with any Personal Data.

As part of the above, we may use cookies and Google Analytics. We may also use remarketing with Google Analytics to advertise online. Third-party vendors, including Google, may show our ads on websites across the Internet. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on visitors’ past visits to our website, as well as report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our website.

VI. PROTECTION OF PERSONAL DATA

Avodah will take reasonable legal, organizational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorized way. We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorized manner and are required to treat your information with confidentiality.

Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means; therefore, any transmission remains at your own risk.

VII. YOUR RIGHT WITH RESPECT TO YOUR PERSONAL DATA

In accordance with applicable laws and regulations, you may be entitled to:

• ask us about the processing of your Personal Data, including to be provided with a copy of your Personal Data;    

• request the correction and/or (in some cases) deletion of your Personal Data;

• in some cases, request the restriction of the processing of your Personal Data, or object to that processing;

• withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);

• request receipt or transmission to another organization, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and 

• complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered as a result of unlawful processing of your Personal Data.

Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

However, choosing not to share your Personal Data with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section II (Use of Personal Data) or that you are unable to make use of the Services. After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

If you wish to make a request to exercise your rights, you can contact us through our contact details set out in Section IX (How to Contact Us) below.

We will screen and verify all requests beforehand. In order to verify your authority to make the request, we may require you to provide supporting information or documentation to corroborate the request.

Once verified, we will give effect to your request within the timelines prescribed by applicable laws.

VIII. AMENDMENTS AND UPDATES

Avodah shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on the Websites. By continuing to use the Apps, Websites or Services, purchase products from Avodah or continuing to communicate or engage with Avodah following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.

IX. HOW TO CONTACT US

If you have any queries about this Policy or would like to exercise your rights set out in this Policy, please contact us at:

Avodah I.T. Services
AR-8, E-nable One bldg. Mabuhay I.T. Park
Ced Ave., National Hi-way,
General Santos City, Philippines
9500

Email: [email protected]

The original of this Policy is written in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.