Bolttech Device Protection Philippines, Inc., together with its affiliates, (“bolttech”) in furtherance of the principles of corporate responsibility and good governance, is mandated to strictly comply with the requirements set forth in Republic Act No. 10173 or the Data Privacy Act of 2012 and its Implementing Rules and Regulations (“DPA”).

bolttech is fully aware of its responsibilities to its subscribers, partners, shareholders, and to the general public; and takes the compliance and commitment seriously. Part of its compliance exercise is to ensure that it only contracts with partners and service providers who have the same commitment to data privacy protection.

Please take note that bolttech may amend this Data Privacy Policy at any time without prior notice. In order to perform under its contract with you, or to fulfil its obligations, bolttech will collect personal information from you which may include, but not limited to, the following:

1. Personal Information such as your name, date of birth, government identification cards or documents, gender, nationality, current mailing address, telephone and mobile phone number, fax number, and email address;

2. Status of products and/or services subscribed with bolttech;

3. Mobile device information such as brand, model, specifications, and its electronic information;

4. Personal interests and preferences;

5. Personal Information needed for marketing preference and participation in surveys, promotional offers, competitions, and contests;

6. Information needed for service request processing and handling;

7. Information needed to process any communication with you such as customer service complaints, feedbacks, and suggestions;

8. Information needed for post-sales services or after-sales maintenance, if any; and

9. Information needed to notify you about the benefits, changes, or upgrades to our Products and Services.

Where processing is not for the performance of a contract or a legal obligation, bolttech may process your Personal Information based on your consent. If you do not provide us with the above-mentioned information, bolttech may not be able to provide you the Products and Services nor respond to any service requests. Furthermore, bolttech may not be able to serve you the notices and updates about new products, services, promotions, or events.

bolttech may disclose the information collected from you to third parties, including service providers and partners engaged by bolttech to deliver its Products and Services or to carry out certain business activities on its behalf, such as, call centers, couriers, authorized repair centers, consultants, authorized agents, independent contractors, and government agencies or appropriate regulatory authorities. Some of these third parties may be located outside the Philippines. You understand and agree that the usage and disclosure of your personal information as set out above signifies your consent and shall remain valid unless you alter or revoke it by giving a written notice to bolttech.

bolttech collects, stores, uses, discloses, transfers, and, where appropriate, erases or anonymises your Personal Information, whether manually or through automated means, only to the extent reasonably necessary to provide the Products and Services, process service requests, administer our relationship with you, comply with legal and regulatory obligations, and carry out other legitimate business purposes described in this Privacy Policy.

We may use automated processing tools to support the administration of service requests, fraud and other financial crime detection and prevention, service validation, and customer support processes. This processing is used to assist us in reviewing information more efficiently and is not intended to serve as the sole basis for decisions that would significantly affect you. Where required by applicable law, we will provide you with additional information regarding such processing.

1. Right to Object – You have the right to indicate your refusal to the collection and processing of your Personal Information, including the processing for direct marketing, automated processing, or profiling. You also have the right to be informed and to withhold your consent to further processing in case there are any changes or amendment to information given to you. Once you have notified bolttech of the withholding of your consent, further processing of your Personal Information will no longer be allowed, unless: the processing is required pursuant to a subpoena, lawful order, or is required by a competent authority; or the collection and processing are undertaken pursuant to any lawful claim.

2. Right to Erasure or Blocking – In the absence of any other legal ground or overriding legitimate interest for the lawful processing of your Personal Information, or when there is substantial proof that Personal Information is incomplete, outdated, false, or has been unlawfully obtained, you may request bolttech to suspend, withdraw, or order the blocking, removal, or destruction of its Personal Information from the filing system of bolttech.

3. Right to Access and Update Personal Information – You have the right to reasonable access, and correction of data collected, under the conditions stipulated by laws and regulations in place, unless bolttech needs to keep the Personal Information for legitimate purposes.

When updating Personal Information, bolttech shall require you to verify your identity before it can act on the request. bolttech reserves the right to reject requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or would be extremely impractical. bolttech provides information access, except when it would require a disproportionate effort. bolttech aims to maintain the services in a manner that protects information from accidental or malicious destruction. Upon deletion of your Personal Information from its services, bolttech may not immediately delete residual copies from its active servers and backup systems.

4. Right to Lodge a Complaint – If you believe that your rights under the DPA have been violated, you have the right to lodge a complaint with the National Privacy Commission, without prejudice to any other legal remedies available under applicable laws.

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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

Details of retention periods for different aspects of your Personal Information are outlined in our retention policy. For queries about bolttech data retention processes please submit a query as set out below.

In some circumstances we will anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may retain this information indefinitely without further notice to you.

bolttech values the trust and relations with our customers, hence, bolttech will ensure to address all Personal Information breaches in relation to data subjects whose Personal Information are held, processed, retained, or shared by bolttech. The standards for breach management implemented by bolttech are guided by the local law and regulation, in coordination with bolttech Group of Companies.

If you have information or have reason to believe that your Personal Information was unlawfully obtained, shared, disclosed, or used for unauthorized purposes, you may contact the Data Protection Officer (DPO) of bolttech.

bolttech ensures that the company meets its requirements and obligations under the applicable data privacy laws, rules, and regulations. If you have any questions, concerns or complaints regarding our compliance with our obligations, the information we hold about you, or if you wish to exercise your rights, we encourage you to first submit a request directly to the DPO. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by the DPA.