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SEATS PRIVACY POLICY

 

1. Acceptance of Policy

 

1.1 This privacy policy (“Policy”) applies to your access to and use of the SEATS website (the “Site”) and/or mobile apps (the “App”)

 

1.2 You shall be deemed to have agreed to this Policy if you access or use any of the Site or App. If you do not agree to this Policy, you shall not be permitted to and shall not access or use the Site or App and you must immediately cease any access to or use of the Site or App.

 

1.3 This Policy may be modified at any time, and such modifications shall be effective immediately upon posting of the modified terms. Your continued access to or use of the Site or App shall be deemed to be your conclusive acceptance of such modified Policy.

 

2. Collection of Your Information

 

2.1 When you access or use a Site or App, we may collect the following information:

 

  • Personal information which is of a personal nature and may be used to identify you as an individual, and provided by you to us, including but not limited to your name, contact number, email address, mailing address and billing information (“Personal Information”).
    • It also includes information about
      • the services provided to you, such as, call/SMS details, location information, and certain information about your rate plans and features, as required by law;
      • the location of your device whenever it is switched on, if you subscribe to location-based services, subject to coverage limitations; and
      • your use of our network, network performance experience, diagnostics, such as, signal strength, dropped calls, data failures, and other network performance issues to help us improve our network and quality of products and services, determine tailored content, and for other legitimate business purposes.
  • Other information involving you, including but not limited to anonymous statistics, records and other information in relation to your browsing of the Site or App. Includes statistical and analytical data, and anonymous and aggregate reports (“Non-Personal Information”).

 

We may also request you to update your Personal Information from time to time. Should you be unable to supply us with the required Personal Information, we may be unable to provide you with your requested products and services, updates on latest offerings, and you may be unable to participate in our events, promotions or other activities.

 

When you use our website and electronically communicate with us, depending on your settings, we may use cookies, web beacons, small data text files or similar technologies to identify your device and record your preferences, with your consent.

 

2.2 Any information disclosed in the public areas of any Site or App (such as any message board or forum) becomes public information. You should exercise caution when disclosing information this way.

 

3. Use of Your Information

 

3.1 You agree and acknowledge that we may use your Personal Information and share your Personal Information with any of our affiliated companies for the purposes of:

 

Provisioning & administration essential to the operation of the Site or App

 

  • Providing you with personalised information and recommendations when using the Site or App. The use of your location for recommending nearby restaurants

  • Enable the use of social interaction on our websites or mobile apps – e.g. allowing you to follow other users, reviewing a restaurant or commenting on a news article

  • Use of your personal data for data analytics to help improve our services

  • Enable us to process bills and payments

  • Respond to enquiries and requests from you or people you have authorised

  • Inform you about service upgrades and updates

  • Inform you of service and security issues

  • Conduct internal audits

  • Meet legal, regulatory and other requirements including providing assistance to law enforcement, judicial and other government agencies

 

3.2 By posting any Non-Personal Information on or via any Site or App, or by otherwise providing any Non-Personal Information (whether electronically or otherwise), you agree and acknowledge that you grant us non-exclusive, perpetual, irrevocable licence to use, disclose, display, reproduce, perform, distribute and modify such Non-Personal Information in any manner and for any purpose as we may deem fit.

 

3.3 We may use your email address to send you Service-related newsletters and notices. We may also use your contact information to send you marketing messages. If you don’t want to receive these messages, you can opt out by following the instructions in the message. If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.

 

4. Sharing your information

 

4.1 We may share your information with:

 

  • Our affiliated companies
  • Business partners and vendors we work with to deliver services you have subscribed to (including restaurants that you have placed a booking with through the service)
  • Industry regulators and other government organisations, as required by local laws and regulations
  • Financial institutions for purposes such as facilitating payments

 

4.2 Your information is disclosed to the above only for relevant purposes (please refer to those mentioned in this Policy) or to protect the interests of our customers.

 

4.3 In some cases, we encrypt, anonymise and aggregate the information before sharing it. Anonymising means stripping the information of personally identifiable features. Aggregating means presenting the information in groups or segments e.g. age groups.

 

4.4 We will also ensure that overseas organisations we work with observe strict confidentiality and data protection obligations.

 

5. Protecting your information

 

5.1 We have implemented stringent measures to secure and protect your information. These include:

 

  • Safeguards to prevent security breaches in our network and database systems
  • Limits on access to information in our systems and the systems of our business partners and vendors
  • Strict verification processes to prevent unauthorised access to information

 

We respect your privacy. We take paramount care in protecting your Customer Data. As such, we secure and protect your Customer Data with proper safeguards to ensure confidentiality and privacy; prevent loss, theft, or use for unauthorized purposes; and comply with the requirements of the law.

 

As communications over the internet may not be secure, we make reasonable and appropriate security arrangements and measures that use a variety of physical, electronic, and procedural safeguards to protect Customer Data. For example, we protect and keep your information submitted through our website safe using a secured server behind a firewall, encryption, and other appropriate security controls. When you enter your information through our website, we encrypt that information using Secure Sockets Layer technology (SSL) so that it cannot be read as the information travels over the internet. We regularly review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to our system and unauthorized alteration, disclosure, or destruction of information we hold.

 

We only permit your Customer Data to be accessed or processed by our authorized personnel who hold such information under strict confidentiality. We restrict access to information to Globe employees, contractors, and agents who need to know such information in order to process it for us, who are subject to strict contractual and technical safeguards and are accountable if they fail to meet these obligations.

 

Furthermore, we only give you or your authorized representative access to your Personal Information. We do not sell your Personal Information to anyone for any purpose. We also do not use nor share your Personal Information with content and/or information providers without your prior request or consent. Personal Information will only be disclosed to third parties in accordance with this Privacy Policy.

 

We keep our records as accurate as possible. If your Personal Information is wrong, we give you ways to update it. Once you have registered as our customer, you may access your account details and correct your Personal Information by contacting Globe Customer Care (+632 7301000 or 211 using your mobile phone) or your relationship manager, as may be applicable; or by visiting any Globe Store or our website at www.globe.com.ph.

 

We keep your Personal Information in our business records, as may be applicable, while you are a customer, or as long as it is necessary to fulfill the purpose for which it was collected, or while it is needed by us for business, tax, or legal purposes. When disposing of your Personal Information, we take reasonable measures to ensure that it is done properly and is not accessible to the public.

 

We are not responsible for information, content, application, product or service that we do not provide. But because we care for you and protect you, we take measures to fight spam, fraud or any unauthorized messages that traverse our network.

 

Photo or video voyeurism, including the publication or broadcast or transmission through our network of any sexual act or any similar activity without the consent of the person involved and under circumstances in which the person has a reasonable expectation of privacy, is prohibited and unlawful with corresponding penalties under the law.

 

Child pornography is also prohibited and punishable by law and our network shall not be used in any manner for the storage, transmission, or dissemination of materials containing child pornography. We will report any instances of such activity that we become aware of to the proper authorities as required by law.

 

6. Third Party Websites

 

6.1 The Site or App may contain hyperlinks to websites which we neither maintain nor control (“Third Party Websites”). You agree and acknowledge that we shall not be responsible for the privacy and security practices employed by any Third Party Website, and shall not be liable for any loss or damage of any kind, including any loss or misuse of Personal Information, arising from access to or use of any Third Party Website.

 

7. Cookies

 

7.1 During your use of a Site or App, we may issue to and request from your computer blocks of data known as “cookies”. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile device browser and is stored on your computer or mobile device hard drive. We may use cookies to obtain certain Non-Personal Information, including in relation to your use of the Site or App. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookies feature.

 

8. High-Level Privacy Principles

 

In addition, we only want the happiest customers so we commit ourselves to abide by GSM (Groupe Speciale Mobile) Association (GSMA)’s high-level privacy principles based on internationally recognized and accepted principles on privacy and data protection as follows:

 

Openness, Transparency, and Notice
We are open and honest with you and will ensure that you are provided with clear, prominent, and timely information regarding our data privacy practices. We will provide you with information about the collection of your Personal Information, access, sharing, and further use of your Personal Information, enabling you to make informed decisions about whether to use a mobile application or service.

 

Purpose and Use
We will limit the access, collection, sharing, disclosure, and further use of your Personal Information to meeting legitimate business purposes or to otherwise meet legal obligations.

 

User Choice and Control
We will give you opportunities to exercise meaningful choice and control over your Personal Information.

 

Data Minimization and Retention
We will collect, access, and use only the minimum Personal Information necessary to meet legitimate business purposes and to deliver, provision, maintain, or develop applications and services. Personal Information will not be kept for longer than is necessary for those legitimate business purposes or to meet legal obligations, and will subsequently be deleted or rendered anonymous.

 

Respect User Rights
You will be provided with information about, and an easy means to exercise, your rights over the use of your Personal Information.

 

Security
Personal Information will be protected, using reasonable safeguards appropriate to the sensitivity of the information.

 

Education
You will be provided with information about privacy and security issues and ways to manage and protect your privacy.

 

Children
An application or service that is directed at children will ensure that the collection, access, and use of Personal Information is appropriate in all given circumstances and compatible with applicable law.

 

Accountability and Enforcement
All responsible persons will be accountable for ensuring that these principles are met.